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    Quantera Global Newsletter – June 2022

    Quantera Global news, developments, and blogs

    Quantera Global news, developments, and blogs

    • A webinar about Benchmark studies was organised by Quantera Global on 18 May. The topics covered during the webinar were: routine services benchmark studies, loan benchmarks and royalty benchmark studies. You can watch the video of the webinar here.
    • On 19 May, Quantera Global, together with Advance Tax Compliance, organised the second session of Masterminds. After three inspiring demos in the innovation centre on use cases of NXP microchips, Paul van Sloun (Senior Tax Director) gave an insightful and interesting presentation on their tax and technology journey (Integrated compliance, Tax reporting and Robotic Process Automation).

    Quantera Global specialties

    In the past month, we completed several challenging and interesting projects that are worth mentioning, such as:

    • Support with the implementation of a Shared Service Center
    • Advising on the TP impact of functions becoming more geographically spread / virtual
    • Determining the credit rating of scale-ups, taking into account current and expected financials

    If you would like to know more about these topics, please feel free to contact us.

    QG Academy Webinars

    In 2020, we started hosting free-of-charge webinars on a variety of Transfer Pricing topics and we are continuing these webinars in 2022. We currently have the following webinars scheduled:

    • 29 November: Outlook 2023
    • 8 December: Outlook 2023 (2)

    To register for one or more webinars, please visit our website https://www.quanteraglobal.com/group-sessions/.

    You can watch our previous webinars here.

    News from around the world:

    The Australian Federal Election was held on 21 May and was won by the Australian Labor Party (ALP). The ALP’s tax plan contains several international tax measures, including a commitment to implement the rules regarding Pillar Two, a limit on debt-related deductions by multinationals and more tax transparency measures.

    The Shenzhen Tax Bureau and Shenzhen Customs published a joint notice on 18 May. The notice is intended to resolve the challenges regarding related-party imports. The notice sets up a collaborative management framework in which customs and tax authorities will work together to avoid double taxation on related-party imports.


    • On 11 May, the European Commission proposed a debt-equity bias reduction allowance (DEBRA). With this proposal, equity will be treated like debt for tax purposes, encouraging companies to become more resilient by reducing the reliance on debt financing and making financing with equity more attractive.
    • The Economic and Financial Affairs Council of the EU (ECOFIN) met on 24 May. The EU minimum tax directive was supposed to be discussed, but due to ongoing negotiations it was removed from the agenda. A new meeting is scheduled for 17 June 2022, and it is hoped to reach an agreement by that date.


    Ireland announced a public consultation on the implementation of the Pillar Two framework on 26 May. Comments can be submitted until 22 July.

    New Zealand
    The Inland Revenue released a consultation document in May. Feedback is welcome on whether and how New Zealand should implement the rules regarding Pillar Two. Comments can be submitted until 1 July.


    • On 3 May, the OECD released its comments received on the public consultation of 14 April on the Extractives Exclusion under Amount A of Pillar One.
    • On 6 May, the OECD announced that it was seeking public comments on the Regulated Financial Services Exclusion under Amount A of Pillar One. The comments received were published on 25 May 2022.
    • On 27 May, the OECD announced that it is seeking comments on the two following consultation documents regarding Pillar One: ‘Tax Certainty Framework for Amount A’ and ‘Tax Certainty for issues Related to Amount A’. Written comments can be submitted until 10 June 2022.

    In Portugal, the monitoring of the Large Taxpayers Unit was extended to entities that enter into or maintain an APA, are subject to CbCR and are a tax resident or have a permanent establishment in Portugal or non-resident entities that have activities subject to supervision of the Portuguese Central Bank.

    The Netherlands
    On 12 May 2022, a judgement from the Dutch Court of Appeal was published. This judgement contained the Court’s view on some important transfer pricing related topics. The Court rejected the conversion from a full-fledged manufacturer to a contract manufacturer, because the operations and risks of the taxpayer did not change after the conversion.

    United Kingdom
    Following a recent consultation, the UK government has decided to delay the implementation of new rules for digital platforms until 1 January 2024. The new rules are an implementation of the OECD model ‘’Reporting rules for digital platforms’’. The postponement of the introduction gives digital platforms more time to prepare for the new rules.


    We are pleased to share the most important national and global developments in tax law that are (closely) related to the transfer pricing world.

    Please feel free to contact us if you have any questions.

    Send an e-mail to TPnews@quanteraglobal.com or call us at +31 88 221 5800 and we will introduce you to the relevant professional.