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    Quantera Global Newsletter – May 2022

    Quantera Global news, developments, and blogs

    Quantera Global news, developments, and blogs

    • On 7 April 2022, a blog was posted on our website about how to prepare for transfer pricing and the benefits of a brainstorm session for your company. You can read the blog here.


    Quantera Global specialties

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

    • We performed a contribution analysis to implement a profit split. You can read more on this topic here.
    • We advised a client on the at arm’s length interest rates on intercompany loan transactions and determined the remuneration of flow-through companies and fully supported them in the implementation of these changes.
      You can read more on this topic here.

    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:

    • 18 May: Benchmark studies
    • 29 November: Outlook 2023
    • 8 December: Outlook 2023 (2)

    To register for one or more webinars, please visit our website https://www.quanteraglobal.com/group-sessions/.

    You can watch our previous webinars here.

    News from around the world:

    Brazil
    On 12 April, the Brazilian tax authority and the OECD Transfer Pricing Unit presented the policy guidelines and main characteristics of the new transfer pricing system to be implemented in Brazil, in order to bring the Brazilian Transfer Pricing system in line with the OECD transfer pricing guidelines.

    Canada
    Canada has released its budget for 2022. The released Budget 2022 proposes the implementation of Pillar Two, along with a domestic minimum Top-up Tax that would apply to Canadian entities of MNEs that are within the scope of Pillar Two. The Canadian Government has launched a public consultation on the implementation in Canada of the OECD Model Rules of Pillar Two and a domestic minimum Top-up Tax. The public consultation will run until 7 July. The Government expects the rules to come into force in 2023.

    Europe
    The Economic and Financial Affairs Council (ECOFIN) met on 5 April. At this meeting, they failed to reach an agreement on the revised compromise text for an EU Minimum Tax Directive. All EU Member States expressed their support, with the exception of Poland, as it allows for parallel implementation of Pillars One and Two. Negotiations with Poland and the other EU member states will continue with the aim of reaching an agreement during the next meeting on 24 May.

    India
    India entered into 62 advance pricing agreements (APAs) in fiscal year 2021-2022, according to a statement issued on 31 March by the Indian Central Board of Direct Taxes (CBDT). This number includes 13 bilateral APAs between India and its tax treaty partners and 49 unilateral APAs.

    Ireland
    On 1 April, the Irish Revenue Commissioners published an updated DAC6 manual to reflect the changes introduced by the Finance Act 2021 and to provide additional guidance. Additional examples have also been added.

    Kenya
    The budget statement for 2022-2023 proposes to enhance the administrative reporting requirements for MNEs with operations in Kenya. Following the proposed enhancement, MNEs would be required to report their activities both in Kenya and in other jurisdictions to the Kenya Revenue Authority.

    OECD

    • The OECD released its Stage 2 peer review on 14 April, monitoring the implementation of BEPS Action 14 in nine selected jurisdictions. The results of the peer review and the peer monitoring process indicate positive changes across all nine jurisdictions, although progress is uneven. The OECD will continue to publish the Stage 2 peer review reports in batches in accordance with the Action 14 peer review assessment schedule.
    • On 14 April, the OECD released a public consultation document regarding the Extractives Exclusion under Amount A for Pillar One of the BEPS 2.0 project. The consultation document is a working document to obtain input from stakeholders. The OECD invited written comments on the draft rules by 29 April.
    • On 25 April, the OECD held a public consultation meeting on the Implementation Framework of the global minimum tax, which discussed the comments received during the public consultation and the mechanisms to be put in place.

    Paraguay

    Paraguay published new guidelines for the preparation of TP reports on 7 April. The new guidelines specify the minimum information required as part of the technical study and the TP report, the due date for filing and the required data on related-party transactions that a taxpayer must provide as part of the transfer pricing information return.

    UAE

    The UAE released a public consultation on the proposed UAE Corporate Tax regime. Comments on this consultation document can be submitted until 19 May 2022. The federal Corporate Tax on Business profits is intended to take effect for Financial Years starting on or after 1 June 2023.

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    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.