In this edition of the newsletter, you will find the most important national and global developments in tax law that are (closely) related to the world transfer pricing.
Please feel free to contact us if you have any questions.
Quantera Global news, developments, and blogs
- We have officially launched our podcast “The Transfer Pricing Method”. Three episodes (1: APAs, 2: Public CbCR, and 3: Brazil’s Adoption of OECD Guidelines) are now available on Spotify, YouTube, and our website. A new episode is coming soon!
- On 3 February, we published a blog on Brazil’s adoption of the OECD Transfer Pricing guidelines. You can read the blog here.
- On 6 February, we published a blog to further elaborate on Pillar One Amount B. You can read the blog here.
- On 20 February, we published a blog on Germany’s Pillar Two Notification Requirements. You can read the blog here.
Quantera Global specialties
In the past month, several challenging and noteworthy projects were successfully completed, including:
- We prepared a loan pricing grid for various intercompany loans to borrowers in different countries around the world with different currencies. The loan pricing grid analyses are used to determine interest rates for the various intercompany loans.
- We assisted a large multinational in the preparation of a sub-master file for their regional activities.
- We assisted a medium sized multinational in designing a TP policy for the head office costs.
If you would like to know more about these topics, please feel free to contact us.
News from around the world:
Belgium
On 31 January, a political agreement was reached that also includes tax measures. The changes include a 10% capital gains tax that might affect individual LPs and the introduction of a competitive tax regime for carried interest.
Chile
On 30 January, the Chilean tax authorities published circular No. 10/2025, providing new instructions on transfer pricing matters, effective as of 1 November 2024. The new instructions relate to the IQ-range, TP adjustments and APAs.
Costa Rica
On 12 February, the General Directorate of Taxation published a notice requiring multinationals with presence in Costa Rica to file an annual transfer pricing information return, if operations exceed CRC 462,200,000. Filing is mandatory as of fiscal year 2024.
Cyprus
On 12 February, the Cypriot tax department announced that no penalties will be imposed for the late submission of the 2022 income tax return (TD4) and the table of summarized information (TSI), if these are submitted ultimately on 31 May 2025.
Denmark
The Danish Authorities propose amendments to its Pillar Two law to incorporate the OECD’s latest Administrative Guidance, and to extend their Top-up tax payment deadlines. The amendments will be effective for fiscal years beginning on or after 31 December 2023.
Israel
On 27 February, the Israelian Tax Authority published a draft tax circular covering two primary topics; local R&D centres compensated with a cost plus, and sale of IP post-acquisition and subsequent conversion to contract R&D.
Poland
On 12 February, Poland’s Ministry of Finance issued a notice listing all jurisdictions with qualified status for Pillar Two purposes.
OECD
- On 24 February, the OECD published a consolidated report on Pillar One Amount B. This Consolidated Report on Amount B bundles all relevant materials published by the Inclusive Framework throughout 2024. The content of the original publications has not been amended or modified; the Consolidated Report on Amount B simply replicates the original content for ease of reference.
- On 27 February, the OECD published “OECD Secretary-General Tax report to G20 finance ministers and central bank governors (G20 South Africa, February 2025)”, setting out recent developments in international tax co-operation, including the OECD’s support of G20 priorities such as the implementation of the BEPS minimum standard, and the Two Pillar solution.
Final words
Thank you for taking the time to read this edition of our newsletter. I hope you found the insights and updates valuable. If you have any questions or would like further information on any of the topics covered, please do not hesitate to reach out to us.
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Best regards,
Adriaan van der Heijden
Director at Quantera Global
