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
- 2023 Pillar 2 pilots: We have launched Pillar 2 pilots with our clients to determine their initial Pillar 2 position. Feel free to contact us for more information to be well prepared before 2024.
- On 18 April, we published a blog on the top four mistakes made when preparing transfer pricing documentation.
- We are hiring! An overview of our vacancies can be found here.
Quantera Global specialties
In the past month, we have completed several challenging and interesting projects worth mentioning, such as:
- Drafting transfer pricing documentation for various enterprises, also considering approaching deadlines for preparation and submission.
- Supporting a multinational enterprise in drafting its intercompany agreements.
- Performing intermediary financing function analyses and analysing the impact of the Dutch Transfer Pricing Decree on these companies.
If you would like to know more about these topics, please feel free to contact us.
QG Academy Webinars
On Wednesday 5 April, we hosted our Quantera Global 10-year anniversary webinar on TP automation.
We discussed the following topics:
- Changes over the past 10 years in relation to TP compliance.
- Growing your business in TP compliance
- The benefits of Coperitas in streamlining TP automation
We have also scheduled the following webinars:
- 11 May – Quantera Global 10 years webinar series: Germany
- 15 June – Quantera Global 10 years webinar series: Poland
For more information or to register for any upcoming webinars, please visit our website https://www.quanteraglobal.com/group-sessions/
You can watch our previous webinars here.
News from around the world:
Australia
- On 6 April, the Australian government issued draft legislation on the implementation of public country-by-country reporting.
- The Australian government released draft legislation under which payments related to intangible assets to related entities in low-tax jurisdictions (i.e. jurisdictions with a corporate tax rate of less than 15%) will not be deductible. The government plans to introduce the legislation on 1 July 2023.
Bahamas
The Bahamas has introduced legislation under which economic substance requirements apply to certain geographically mobile income sectors. Under the new legislation, businesses need to determine whether they are in scope of the requirements and whether they perform relevant activities that fall under the scope of the new legislation.
Ireland
The Irish government has released a Feedback Statement and consultation on the implementation of the Pillar Two Model Rules. The consultation will remain open until 8 May 2023.
Luxembourg
The Luxembourg Minister of Finance has submitted to parliament a draft bill introducing, among other things, a framework for multilateral and bilateral Advance Pricing Arrangements. The introduction of new transfer pricing documentation requirements when specific thresholds are met is also included.
Mongolia
Mongolia has committed itself to implement the international Standard for Automatic Exchange of Financial Account Information in Tax Matters by 2026. According to the Minister of Finance of Mongolia, this will enable the country to better combat tax evasion.
Poland
- The Minister of Finance of Poland has published guidance on the transfer pricing application of the resale price method (RPM). The guidance includes criteria for comparability of transactions and entities and a comparison with other transfer pricing methods.
- A Polish Court issued a ruling that dismissed a taxpayer’s complaint about the tax authority’s refusal to exempt certain payments to a Dutch parent company from withholding tax. Under Polish law, withholding tax may be avoided if the tax authority issues an exemption opinion. The tax authority refused to do so because the dividends were tax-exempt in the Netherlands.
United Kingdom
The United Kingdom will, for the first time, mandate a standardised approach to transfer pricing documentation. For accounting periods beginning on or after 1 April 2023, it will be mandatory to prepare a Master File and local country files. The previously proposed Summary Audit Trail has been delayed until further notice.
Zimbabwe
Zimbabwe has joined the Global Forum. The Global Forum is a multilateral body designed to ensure that jurisdictions around the world exchange information with each other, both automatically and upon request.
