Quantera Global Newsletter – June 2023 Schedule a call

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    Quantera Global Newsletter – June 2023

    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.  

    Quantera Global news, developments, and blogs 

    • On 11 May 2023, together with our German Quantera Global network partners, we hosted a webinar on key developments in the German transfer pricing landscape over the past decade. Interested in the recording? Please e-mail qgacademy@quanteraglobal.com. 
    • On 23 May, we published a blog on transfer pricing developments in the UK in recent years. You can read the blog here. 
    • On 24 May, the Dutch Association of Tax Advisors organised its second seminar on the Dutch transfer pricing decree and other current affairs, in particular the Dutch APA practice. Our colleague Rudolf Sinx was chairman of the day. Together with delegates from the Dutch Ministry of Finance and the Dutch Tax Administration, we look back on a very successful and inspiring seminar. It was an educational session for both participants and presenters. 

    Quantera Global specialties 

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

    • Assisting a large multinational in the set-up of a global transfer pricing model. 
    • Supporting a Dutch multinational in the conclusion of an Advance Pricing Agreement with the Dutch Tax Authorities. 
    • Assisting a large multinational with the application of the Dutch innovation box. 
    • We assisted one of our alliance partners in the preparation of TP documentation with respect to the Netherlands. 

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

     QG Academy Webinars 

    On Thursday 11 May, we hosted our Quantera Global 10-year anniversary webinar on the key-developments for transfer pricing in Germany.  

    We discussed the following topics: 

    • Key developments and timeline of the regulatory TP framework in Germany; 
    • Comment on history including how to deal with unclear legal framework until formalisation after 2001; 
    • Documentation, administrative requirements, and burden of proof; 
    • Recent tax audit experiences. 

    We have also scheduled new webinars in July, August and September. 

    13 July 2023 United States
    31 August 2023 Portugal & South America
    21 September 2023 Asia/China 

    For more information or to register for any upcoming webinars, please visit our website https://www.quanteraglobal.com/group-sessions/

    You can watch our previous webinars here.  

    News from around the world:   

    The Federal Treasurer delivered the Australian 2023/24 Federal Budget on 9 May. The Federal Budget included the announcement that Australia will adopt the Pillar Two rules from the OECD effective 1 January 2024. 

    On 10 May, the Brazilian Federal Senate unanimously passed the Bill approving a new TP framework in Brazil that is in accordance with the OECD TP Guidelines. The approval of the draft legislation is one of the final steps for the implementation of the new TP system that aligns with the OECD Guidelines. 

    Channel Islands and Isle of Man
    The governments of the Channel Islands (Guernsey and Jersey) and the Isle of Man published an agreed approach for the implementation of Pillar Two of the OECD. The aim is to implement the new legislation by 2025. 

    European Commission
    The European Commission published a political agreement reached by EU Finance Ministers. The new tax transparency rules in the agreement, published on 16 May 2023, will be used for all service providers that facilitate transactions in crypto-assets for customers resident in the EU. 

    The Finance Bill 2023 was published by the National Treasury. The Finance Bill proposes a few new tax measures, including changes to some definitions for purposes of CbC-reporting. 

    New Zealand
    On 18 May 2023, the Taxation Bill was introduced by the Minister of Revenue. The government announced that it will implement the legislation for Pillar Two of the OECD’s Global Anti-Base Erosion rules.  

    Qatar has published amendments to the Executive Regulations to the Income Tax Law on 16 May 2023. The amendments include a change in the definition of a permanent establishment (PE) and new economic substance rules. 

    The Netherlands
    In response to parliamentary questions, the State Secretary of Finance stated that the 2024 Minimum Tax Bill is likely to be presented before the summer of 2023 and should be implemented before 31 December 2023. 

    United Arab Emirates
    The UAE Ministry of Finance published guidance on the requirements for transfer pricing documentation on 11 May 2023. The guidance specify the requirements when a taxpayer has to maintain a Local file and/or Master file. 

    United States
    On 2 May, the US Department of Treasury and the Internal Revenue Service (IRS) published proposed regulations. The proposed regulations make it more appealing to repatriate certain intangible property (IP) subject to IRC Section 367(d). 


    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.