Quantera Global Newsletter – March 2026
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 transfer pricing world.
Please feel free to contact us if you have any questions.
Quantera Global news, developments, and blogs
- Quantera Global is delighted to announce the appointment of Dennis van Zoelen as Counsel Pillar Two at Quantera Global, as of 1 February 2026.
- QG has strengthened its position in France by welcoming Phronesis Avocat, a trusted law firm with strong transfer pricing capabilities, to its network. Press release can be found here.
- The QG Network is expanding in the United Kingdom, with our long-standing alliance partner MUSE Strategy expanding into the UK and bringing its UK branch into the network. Press release can be found here.
- Our international alliance network is open to new partners. We welcome transfer pricing specialists and independent professionals, along with accounting, audit, tax, and legal firms, and other like-minded organisations that value quality, clarity, and care.
More information is available here, including the option to schedule an introductory call.
Quantera Global Specialties
In the past month, we successfully completed several challenging and noteworthy projects, including:
- Finalising our TP design for a global business restructuring, client being a stock-quoted MNE in the b-to-b market. This has been a wide-scoped project in which we have touched upon all managerial layers of the organisation.
- We finalised our work on the restructuring of a Europe-based medical services MNE by redesigning its TP model. This has led to better managerial steering and control, improved cash management, and it provided quite significant tax savings as well.
- We supported an MNE by centralizing the IP after integrating an acquired business and the related valuation.
If you would like to know more about these topics, please feel free to contact us.
News from around the world:
Belgium
On 9 February, the Belgian tax authorities confirmed that advance payments of Pillar Two IIR top-up tax must be made per entity, rather than at group level. Each entity must use its own structured communication via MyMinfin or generate it through the FPS Finance payment tool. The approach for advance payments of the domestic top-up tax remains unchanged.
Bulgaria
On 3 February, the Bulgarian Supreme Administrative Court issued its ruling on the Cargill Bulgaria EOOD case. The dispute centred on whether intragroup sales were properly priced in accordance with the arm’s length principle. The tax authorities challenged the use of the Cost Plus Method as profit level indicator within the Transactional Net Margin Method (“TNMM”) for a sales transaction and adjusted the results to a TNMM with a return on sales profit level indicator. The Supreme Administrative Court held that the first instance court had not provided sufficient evidence or reasoning and therefore annulled its decision and returned the case for reconsideration.
European Council
On 17 February, the European Council updated the EU list of non-cooperative jurisdictions for tax purposes. The Turks and Caicos Islands and Vietnam were added as countries and the Council and the following three countries were removed: Fiji, Samoa and Trinidad and Tobago.
France
On 2 February, France´s Parliament adopted the Finance Act for 2026, which will be formally enacted after publication in the Official Gazette. Key corporate measures include Pillar Two updates incorporating the OECD June 2024 administrative guidance and implementing DAC9 on the exchange of Pillar Two information.
India
In February, the Finance Minister presented the 2026–2027 Union Budget, proposing significant transfer pricing updates to safe harbours and APAs, including a consolidated “IT services” category with a 15.5% net cost-plus margin and a higher eligibility threshold (INR 20 billion), alongside broader direct and indirect tax measures ahead of the Income-tax Act, taking effect on 1 April 2026.
Italy
On 6 February, the tax administration published Pillar Two tax return forms and instructions on its dedicated e-filing platform. A single return covering QDMTT, IIR and UTPR must be filed alongside the GIR (GloBE information return), and it must be submitted even where no top-up tax is due for the year.
Malta
On 20 February, Malta published an Official Gazette amendment to its Pillar Two rules confirming that Maltese constituent entities are exempt from filing the GloBE Information Return and related notifications. In practice, groups must appoint a designated filing entity in another jurisdiction with a qualifying exchange mechanism (DAC9 or the GIR MCAA) to file the GIR, while Maltese entities must provide the required information to that filer.
OECD
- On 2 February, the OECD published the 2026 edition of the updated Manual on Effective Mutual Agreement Procedures (MEMAP). This provides non-binding practical guidance for competent authorities and taxpayers on how to run MAP cases effectively. The revised manual includes 59 best practices, adds detailed procedural and organisational guidance to support dispute prevention, and for the first time provides dedicated best practices and practical templates on MAP arbitration.
- On 17 February, the OECD released the Amount B Pricing FAQs (link here) and published the 2026 version of the Amount B Pricing Automation Tool (download Excel here). The FAQs provide practical clarifications to support consistent application of the simplified and streamlined approach for baseline marketing and distribution activities (Amount B). Topics covered include points on the pricing matrix tolerance, working capital and the accounts payable guardrail, and how certain adjustments should be treated.
Poland
The following update has been provided by our network partner, BTTP.
- Changes to Tax Limitation Rules and Their Impact on TP/TPR Obligations
A draft amendment was submitted to the Polish Parliament on the Tax Ordinance and the Fiscal Penal Code, which changes the rules on limitation periods and the suspension of limitation, affecting how long the tax authorities will be able to revisit settlements covered by TP reporting (TPR). At the same time, the draft restricts the current practice of suspending the limitation period by initiating fiscal penal proceedings but introduces other mechanisms that extend limitation periods in certain situations. For taxpayers, this makes proper planning of archiving and the availability of TP/TPR documentation particularly important. [link here]
- Poland intensifies tax verification in 2025
The Polish National Revenue Administration (KAS) published the results of audits conducted in 2025 as part of the verification of the correctness of tax settlements. KAS reported that findings from verification and control activities increased by 29.1% compared to 2024. The number of audit activities also increased by 9.4%. At the same time, KAS has continued to shift its operating model: fewer traditional tax audits and more efficient verification checks. The results also indicate better targeting of activities: despite a 27.4% decrease in the number of customs and fiscal audits, the value of findings from those audits increased by 46.4% (link here).
- National Tax Information (KIS) on IP Box: allocating income to IP is key
An individual interpretation of the Director of KIS clearly shows how IP Box can be approached in practice for businesses that commercialise their own solutions and embed qualifying IP in the price of sold products. The authority stresses that the rules give taxpayers flexibility as to how the required records are maintained, and that the key is to organise the data in such a way that it is possible to demonstrate which part of the income results from intangible assets and R&D work, and which part comes from other elements of the business. This is a valuable indication for entities investing in the development and protection of IP, as it shows that – with an appropriate methodology and documentation as well with TP policy – IP Box can be applied in an orderly and predictable manner (link here).
- Difficulties in interpreting the transfer pricing adjustment provision
Article 11e of the CIT Act has long caused disputes in Poland due to the unclear distinction between transfer pricing adjustments and ongoing settlement corrections. In practice, doubts concern in particular annual profitability adjustments and when they still constitute an arm’s-length adjustment of the result, versus when they should be treated as corrections to specific invoices.
In this context, an individual interpretation of the Director of KIS shows how the authority understands the application of Article 11e in practice and where it places the boundary between a TP adjustment and a current settlement correction. The authority confirmed that such a collective year-end adjustment, based on actual data and an allocation key, may be treated as a TP adjustment serving to bring the outcome to arm’s length, provided the statutory conditions are met, demonstrating market conditions during the year and having confirmation of the adjustment on the part of the related entity and a basis for the exchange of tax information with the country of its residence.
- Municipalities and transfer pricing: dispute over exemption from TP documentation and TPR reporting
In Poland, the question of whether, and when, municipal companies can benefit from the exemption from TP documentation obligations, under Article 11n of the Corporate Income Tax Act (CIT) is still being decided in the courts. This is confirmed by a judgment of the Voivodeship Administrative Court (WSA) in Rzeszów, which overturned an individual interpretation of the Director of KIS in which the authority stated that municipal companies cannot apply the Article 11n exemption where both capital and personal links exist at the same time. The court did not share this view and indicated that such personal links are typically an element of the municipality’s ownership supervision over its companies and therefore still arise from the relationship with the local government unit.
Qatar
On 12 February, the Council of Ministers published an Official Gazette resolution setting out detailed rules for applying Qatar’s Pillar Two DMTT and IIR under Law No. 22 of 2024 (applicable for fiscal years starting on or after 1 January 2025). The resolution confirms that these rules should be interpreted in line with OECD GloBE materials. It also aims to align the DMTT with qualified DMTT requirements and includes the transitional CbC reporting safe harbour, as well as other GloBE exclusions and safe harbours.
Slovenia
On 13 February, the Slovenian tax administration made available the forms for the IIR and UTPR top-up tax return and the DMTT return. The DMTT return is due within 15 months after year-end (18 months for the transitional year), in line with the GIR deadline, while the IIR and UTPR return is due within 30 days after the GIR filing deadline.
Ukraine
On 24 February, the Ministry of Finance published a draft bill proposing amendments to Ukraine’s transfer pricing rules and opened it for public consultation. The proposal aims to further align Ukraine’s TP framework with EU standards and the OECD approach, including updates connected to OECD TP guidance and BEPS Actions 8-10.
Final words
Thank you for taking the time to read this edition of our newsletter. I hope you found the insights and updates valuable. Do you have any questions or need further information? Contact us today to get expert advice on worldwide transfer pricing matters and developments.
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Best regards,
Adriaan van der Heijden
Managing Director at Quantera Global
