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Quantera Global Newsletter – March 2020

In this Newsletter we would like to keep you up to date on relevant Transfer Pricing developments in an
accessible manner.

We are pleased to keep you informed about 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.
You may send an e-mail to marketing@quanteraglobal.com or call us at +31 88 221 5800 and we will introduce you to the relevant professional.



Developments and blogs:

  • Audit Framework:
    • The Malaysian Inland Revenue Board (MIRB) released the Transfer Pricing Audit Framework 2019 (TPAF 2019) to replace the 2013 version.
      Read our blog on this topic here
  • Country by Country reporting:
    • The OECD has released a consultation document on the review of Country-by-Country Reporting and invites public input on BEPS action 13 points.
  • Digital Economy:
    • Inclusive Framework: the 137 OECD members adopted the OECD’s proposed “unified approach”, including important modifications and clarifications, as the basis for further negotiations on pillar one.
  • Financial transactions:
    • On the 11th of February 2020 the OECD released its new transfer pricing guidance on financial transactions which will be included in the OECD Transfer Pricing Guidelines.

Read our blog on this topic here.

  • General OECD publications:
    • The OECD shared its tax agenda and the progress on transparency and the exchange of information for tax purposes (OECD Secretary-general tax report).

 

News around the world:

  • Australia: the ATO has issued a tax alert and will be reviewing international arrangements regarding possible mischaracterisation of Australian DEMPE activities of intangible assets, in order to determine whether these arrangements are at arm’s length.
  • Belgium: the Belgian Tax Authorities released the final version of its circular on transfer pricing.
  • Brazil: Brazilian Administrative Tax court: a McDonald’s subsidiary in Brazil has to pay withholding tax on payments made under a cost-sharing agreement.
  • British Virgin Islands: the British Virgin Islands International Tax Authority announced that starting March, they will be ready to accept multinational group country-by-country reporting filings for tax purposes. The filing will be done via the electronic portal only.
  • Netherlands: an updated Q&A with regard to the “Besluit vooroverleg rulings met een internationaal karakter” was published by the Dutch Tax Authorities to provide some new insights regarding the current Dutch ruling policy.
  • Sweden: PUMA’s group distributor in Sweden has had its taxable income adjusted by the Swedish tax agency. Not being able to control the main risks, the distributor should not have carried local market risk.
  • Turkey: Turkey has implemented the OECD BEPS action 13 recommendations concerning TP documentation and reporting requirements. Documentation includes: Master File, Local File & CbC reports.
  • USA: U.S. Court of Appeals agrees with IRS’ view that stock-option compensation should be included among the assets that are valued for U.S. tax purposes when moving intangible assets abroad.

 

Quantera Global Academy:

The curriculum of the Quantera Global Academy until May is available. For more information: https://www.quanteraglobal.com/qg-academy/

Private sessions are offered as well.

  • The next ‘Quantera Global Academy’ is on 18 March. The topic is Transfer Pricing and Risk Management. During the course of TP Risk Management: Compliance and Organisation insights are provided on how to deal with the compliance burden effectively and organise the management of this burden in your organisation.

This information is intended only as a general update for interested persons and should not be used as a basis for decision-making. For further details please contact Quantera Global, Eindhovenseweg 128, 5582 HW Waalre, the Netherlands,
phone: +31 88 221 58 00, e-mail: marketing@quanteraglobal.com

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