Quantera Global Newsletter – October 2022 Schedule a call

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    Quantera Global Newsletter – October 2022

    Quantera Global news, developments, and blogs

    • Recently, our colleague Stefan Ubachs wrote a contribution for the Dutch NTFR on the new Dutch Transfer Pricing Decree (in Dutch). If you have a subscription on NTFR, the contribution can be accessed as NTFR 2022/3141.
    • Quantera Global is 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.

    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.

    • 13 Oktober: Master Minds Dispute Resolution
    • 10 November: Master Minds Tax & Technology

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

    News from around the world:

    Bulgaria
    For Bulgaria, the Multilateral Convention to implement Tax Treaty related measures to prevent Base Erosion and Profit Shifting will enter into force on 1 January 2023.

    Europe
    In a statement issued on 9 September 2022, EU member countries France, Germany, Italy, the Netherlands and Spain committed to implementing Pillar Two without delay in 2023.

    Germany
    The German Federal Ministry of Finance has published draft legislation on the submission of transfer pricing documentation in case of a tax audit.

    International Monetary Fund
    The IMF has published a working paper entitled “Keeping It Simple”.  This paper t focuses mainly on simplifying transfer pricing.

    Ireland
    Ireland’s Minister of Finance presented the Budget of 2023 on 27 September. Ireland will follow the OECD Two-Pillar Agreement commitments, but legislation regarding minimum tax rules is not expected in this year’s Finance Act.

    Italy
    The Italian Parliament recently passed legislative measures to accelerate tax disputes while increasing the quality and efficiency of decisions of tax courts.

    OECD

    • The OECD has announced that Director Pascal Saint-Amans will retire by the end of October 2022.
    • The OECD has published its Bilateral Advance Pricing Arrangement Manual. In this manual, the OECD aims to highlight best practices for the BAPA process to be followed by competent authorities.

    Saudi Arabia
    The Zakat, Tax and Customs Authority (ZATCA) of Saudi Arabia has published it results on Transfer Pricing Bylaws, after receiving comments on the public consultation.

    Slovakia
    The parliament of Slovakia has proposed changes to existing transfer pricing rules. The changes will take effect on 1 January 2023 and include a direct reference to the OECD guidelines.

    Switzerland
    Switzerland has temporarily suspended all forms of tax-related information exchange, including financial accounts and country-by-country reports.

    The Netherlands
    On 20 September 2022, the Dutch Government made its budget proposals and other important legislative developments for 2023 and 2024 public. The proposals are expected to be finalised in December 2022 after being reviewed and discussed in the Dutch Parliament.

    United Kingdom
    The UK Chancellor of the Exchequer presented a mini-Budget on 23 September. The mini-Budget is part of the Government’s Growth Plan. One of the proposals in the mini-Budget is not to raise the corporate tax rate to 25% as planned.

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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.

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