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 and Developments
- Quantera Global and OBENHAUS International Tax, a Swiss based consulting firm focusing on all cross-border tax-related issues, form a strategic partnership. For more information click here.
Quantera Global Specialties
In the past month, several challenging and noteworthy projects were successfully completed, including:
- We prepared an elaborate CUP analysis for specific procurement transactions;
- We assisted a large multinational with the treatment and allocation of start-up losses from a transfer pricing perspective; and
- For a large multinational we prepared the required transfer pricing documentation for countries across the globe.
If you would like to know more about these topics, please feel free to contact us.
Quantera Global Blogs
- On 18 April, we published a blog on Germany’s New Transaction Matrix. You can read the blog here.
- On 2 May, we published a blog on understanding location-specific advantages, drawing insights from OECD Guidelines and the UN Model. You can read the blog here.
- On 13 May, we published a blog on mastering operational transfer pricing, featuring insights from industry experts. You can read the blog here.
News from around the world:
Belgium
Belgium has published the template for the qualified domestic minimum top-up tax return. The first deadline for filing the return is 30 November 2025. Guidance on this template and the XSD-schema will be published later.
Bulgaria
Bulgarian Authorities published several amendments to the Bulgarian Pillar Two legislation, including safe harbors, the Domestic minimum top-up tax (DMTT), the switch-off rule and additional (OECD) guidance.
European Union
- On 3 April, a nonbinding opinion of the Advocate General of the Court of Justice of the European Union (CJEU) was published, regarding a Romanian Tax dispute. This opinion may provide more clarity on the VAT aspects for intra-group transactions and transfer pricing arrangements, if followed by the CJEU.
- On 8 April, a Council Directive was adopted that will amend the directive on administrative cooperation in the field of taxation (DAC 9). The directive extends cooperation and information exchange regarding Pillar Two.
Germany
- On 2 April, The German tax authorities provided administrative guidance on the transaction matrix. The transaction matrix is a new requirement that needs to be submitted within 30 days when a tax audit starts. The transaction matrix is also relevant for previous tax years.
- On 9 April, Germany published the German coalition agreement, containing tax changes in various areas, including Pillar Two and the Corporate Income Tax rate.
India
Indian Tax Authorities expanded the scope of the transfer pricing safe harbor rules. These changes include the increase of the safe harbor threshold from 2 billion INR to 3 billion INR for certain transactions (“eligible international transactions”), such as IT services, contract R&D, loans and guarantees.
Luxembourg
- Luxembourg ratified the tax treaty with Colombia on 2 April. The treaty will be applicable starting from 1 January 2026, if Colombia also ratifies the treaty in 2025.
- On 17 April, Luxembourg’s Administrative Court published a decision regarding the requalification of interest-free loans to equity for tax purposes. The Court reaffirms that the qualification of financial instruments depends on its economic reality instead of its legal form, continuing the application of the substance-over-form principle.
OECD
From 7 to 10 April the OECD held a meeting for the BEPS project. In a statement published by the OECD, the implementation of Pillar Two and the negotiations regarding Pillar One were highlighted to be very important to provide clarity and stability in the international tax system.
Poland
On 7 April, proposed changes to the Pillar Two rules were added to the Council of Ministers’ legislative work and policy agenda. The Council of Ministers is anticipated to approve these amendments in the third quarter of 2025.
Spain
Spain’s Cabinet approved a Decree which implements the OECD’s Pillar Two global minimum tax as provided under the EU Minimum Tax Directive.
United Kingdom
- On 26 March, the UK’s Treasury department announced a consultation on developing a new process giving major investment projects increased tax certainty in advance. In addition, the government indicates its intention to provide certainty regarding the treatment of cost contribution agreements (CCAs) through the existing legislation on advance pricing agreements (APAs)
- On 28 April, the UK’s government announced an open consultation on reforming UK law in relation to transfer pricing, permanent establishment and Diverted Profits Tax. The consultation includes two transfer pricing related topics. One related to the amendment of the transfer pricing exemption for small and medium sized enterprises, and one on requiring multinationals to provide HMRC with information on cross-border related party transactions.
United States
On 22 April, the IRS released a memorandum, providing guidance to its employees on how to review APA (pre-filing) requests before they can be accepted in the advance pricing and mutual agreement program.
Qatar
Qatar has introduced the Pillar Two global minimum tax rules. This includes the implementation of an income inclusion rule (IIR) and a domestic minimum top-up tax (DMTT), but does not include the undertaxed payments rule (UTPR). The new legislation will be effective for fiscal years starting on 1 January 2025 and onwards.
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 questions or need further information, please don’t hesitate to contact us.
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Best regards,
Adriaan van der Heijden
Director at Quantera Global
