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    Quantera Global Newsletter – March 2022

    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:

    Formed in freedom like us. What more reason should you have to fight for it? Our thoughts are with Ukraine.

    Quantera Global blogs
    – On 11 February, we posted an announcement on our website welcoming Monika Šapranauskienė as the head of Quantera Global Baltic.
    – On 23 February, another blog was posted on how to turn an aggressive audit into an opportunity.
    – Rudolf Sinx, one of the founders of Quantera Global, shared his views on APAs in the last NOB (Dutch Association of Tax Advisors) newsletter. He answered five questions on this subject, in the section “vijf vragen aan”. For the full article (in Dutch), click here.

    Quantera Global specialties
    In the past month, we completed several challenging and interesting projects that are worth mentioning, such as:
    – As previously shared, Quantera Global in cooperation with AARC has been selected by the EU to support Poland and Slovakia in streamlining their processes of conducting Advance Pricing Agreements. After intensive preparatory work, we have just completed a multi-day workshop with the Polish and Slovakian APA teams.
    – We advised a client on a new (intercompany) treasury policy and fully supported the implementation of the new model, including transfer pricing documentation and benchmark studies.

    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:
    – 14 April: Transfer Pricing and Financial Transactions
    – 18 May: Benchmark studies
    – 29 November: Outlook 2023
    – 8 December: Outlook 2023

    To register for one or more webinars, please visit our website

    You can watch our previous webinars here.

    News around the world:

    The Australian Taxation Office has won a dispute, showing that the court considers expert witnesses and their experience and creditability important in transfer pricing disputes.

    On 26 January, it was announced that tax authorities across China will use big data to tackle tax evasion by multinational companies and individuals. By using big data, they also want to ensure taxpayer compliance.

    A new guidance was published on 31 January 2022, in which the Danish Tax Agency issued a clarification on the master file filing requirements. If a taxpayer is unable to provide a master file for a particular year, they may be granted a temporary postponement if they meet three specific conditions.

    The thresholds for taxpayers to qualify for the ‘cooperative compliance regime’ were renewed and lowered by a ministerial decision, published on 8 February 2022.

    – The OECD opened a public consultation on 4 February by releasing the draft rules for nexus and revenue sourcing under Pillar one amount A. The consultation has closed, and the OECD has now released the comments it received on the draft rules.
    – The OECD opened another public consultation under Amount A of Pillar One. They asked for comments on the draft rules for tax base determinations. The deadline for public input was 4 March 2022.
    – On 28 February, the OECD released a third batch of updates to the transfer pricing country profiles on its website. This update brings the total number of countries covered to 91.

    The Supreme Administrative Court has determined that the concept of transaction must be defined broadly, as there is no legal definition of it.

    On 16 February, the Romanian government approved organisational changes for the Ministry of Finance and the National Tax Agency. The advance tax rulings unit will be the responsibility of the Ministry of Finance.

    On 18 February, the Minister of Finance announced that Singapore will explore a top-up tax. The top-up tax is a response to the global agreement that MNEs pay a minimum effective tax rate of 15%.

    South Africa
    In February, South Africa released a new draft interpretation note on intragroup loans. The draft largely follows the financial transactions guidance from the OECD Transfer Pricing Guidelines.

    Thailand and Vietnam
    Thailand and Vietnam signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (‘’MLI’’) on 9 February 2022. With the signing of the MLI Thailand and Vietnam will, among other things, adopt changes to the Mutual Agreement Procedure provisions.


    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 or call us at +31 88 221 5800 and we will introduce you to the relevant professional.