Quantera Global Newsletter – November 2022 Schedule a call

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    Quantera Global Newsletter – November 2022

    Quantera Global news, developments, and blogs

    • On 13 October, Quantera Global organised a Master Minds session where tax experts of various large Multinationals shared their knowledge on dispute resolutions. 
    • On 20 October, Quantera Global published a blog regarding the recently updated Dutch Decree on Profit Allocation for Permanent Establishments. You can find our blog here. 
    • On 7 December, the NOB (Dutch Association of Tax Advisors) will host a seminar on the new Dutch Transfer Pricing Decree. Rudolf Sinx, one of the Managing Directors of Quantera Global, will be one of the presenters on behalf of the NOB. If you are a member of the NOB and are interested to join, please click here. 
    • We are hiring! An overview of our vacancies can be found here 

    If you would like to know more about these topics, please feel free to contact us.

    Quantera Global specialties

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

    • Full functional and value chain analyses for a large MNE with newly acquired businesses in the Netherlands. 
    • Reviewing a newly incorporated cash pool set-up and assisting the company in setting at arm’s length pricing (i.e. interest rates, remuneration cash pool leader and guarantee fee pricing). 
    • Completing a valuation of a business restructuring, where the company transferred part of its business to another country and entity. 

    If you would like to know more about these topics, please feel free to contact us. 

    QG Academy Events & 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:

    • 29 November: Outlook 2023
    • 8 December: Outlook 2023 (2)

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

    In addition to our webinars, we have scheduled two Master Minds. These exclusive Master Minds take place at our office in Waalre and are by invitation only.

    • 10 November: Master Minds Tax & Technology

    If you are interested in attending, please indicate this to your QG contact.

    News from around the world:

    The Brazilian Superior Court of Justice has issued a decision on the application of transfer pricing rules to determine the parameter price resulting from the utilization of the Brazilian Resale Price Minus Profit Margin.  

    The CJEU has issued a decision confirming that an additional charge by Germany does not violate the right to freedom of establishment. Germany imposed this additional charge for lack of sufficient documentation. 

    Costa Rica
    On 7 October, a new resolution was published by the Costa Rican General Directorate of Treasury. This resolution contains new criteria for selecting tax payers and beneficiaries for audits.  

    On 13 October, the Tax Authority of Cyprus announced that the bilateral Competent Authority Arrangement for the exchange of CbC reports between the US and Cyprus is expected to take effect for fiscal years from 1 January 2022 onwards.  

    The ECOFIN took place on 4 October, where the Finance Ministers agreed on a revised EU list of non-cooperative jurisdictions.  

    The Tax Authority of Ecuador has modified its tax treatment and definitions for Tax Havens, Special Tax regimes and Minor Tax Jurisdictions.  

    European Commission
    On 13 October, a consultation was opened on BEFIT.  

    At the G20 meeting on 12 and 13 October, the Finance Ministers expressed the need for swift implementation of the new BEPS 2.0 rules in their national legislation. 

    Following the adoption of BEPS action 13 principles, Israel introduced new transfer pricing rules in its national legislation.  

    The Korean Supreme Court has issued a decision with regards to transfer pricing adjustments and customs value of imported goods. The court decided that transfer price adjustments should be added to the customs value of imported goods when there is a direct link. 


    • On 6 October, the OECD published a report regarding considerations for the implementation of Pillar Two.  
    • On 6 October, the OECD published a new report regarding the use of tax incentives from a Global Anti-Base Erosion perspective.  
    • On 10 October, the OECD published a new global tax transparency framework on the subject of exchanging information with regards to crypto-assets.  
    • The OECD released a statement seeking comments on the Administration and Tax Certainty Aspects of Amount A of Pillar One.  

    The Spanish Supreme Court has issued a decision with regards to dynamic interpretation of tax treaties.  

    South Africa
    On 14 October, South Africa published guidance on the definition of “associated enterprises” in connection with transfer pricing rules. 

    New legislation has been proposed on cross-border divisions, conversions and mergers. This legislation is expected to become effective as of 31 January 2023. 

    The Netherlands 

    • A court case on 30 September was ruled in The Netherlands on the valuation of business activities. The court relied on the advice of an expert and adjusted the profit according to the expert’s calculations. 
    • The Dutch Ministry of Finance launched an internet consultation on a legislative proposal to implement the Pillar Two rules per 31 December 2023 in domestic legislation. 

    United Kingdom
    On 17 October, the UK Chancellor of the Exchequer reversed most of the measures from the Growth Plan.


    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.