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 Network
- QG has strengthened its position in Poland by adding BTTP, a trusted firm providing tax, legal, and accounting services, to its network. Press release can be found here.
- The QG Network is expanding to Denmark, with Censio Tax, our valued partner firm in Sweden, opening a new office in Copenhagen. Press release can be found here.
- Our international transfer pricing network (QG Network) is open to new partners. We invite TP specialists, independent professionals, accounting, audit, tax and legal firms, and like-minded organizations that value quality, clarity and care to join us. More information on this topic, including a link to arrange an introductory call with us, can be found here.
Quantera Global news, developments and blogs
- On 15 September, we published a case study on the automating of operational TP and controls for a listed SaaS company. You can read the case study here.
- On 30 September, we published a webinar on Tax & TP in business transformations, together with Blue Turtle Tax. You can watch the webinar here.
Quantera Global Specialties
In the past month, several challenging and noteworthy projects were successfully completed, including:
- Preparation and filing of the Belgian Local File 275 Form for multiple clients.
- Advising a Dutch company on key TP considerations for setting up its business operations in the United States.
- Meeting with the Dutch tax authorities regarding various intercompany cost recharges.
If you would like to know more about these topics, please feel free to contact us.
News from around the world:
Albania
Albania has signed the “Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule”, streamlining the swiftly implementation of the Pillar Two Subject to Tax Rule in existing bilateral tax treaties without the need for bilateral negotiations.
Brazil
The update below is provided by our network partner Castro Barros.
Recently, the Brazilian tax framework has undergone significant changes along two main axes: (i) the new transfer pricing rules; and (ii) the forthcoming implementation of the goods and services tax (IBS) and the contribution on goods and services (CBS) under the consumption tax reform.
Law No. 14,596/2023 aligned transfer pricing standards for Corporate Income Tax (IRPJ) and Social Contribution on Net Profit (CSLL) with the OECD arm’s length principle, while Normative Instruction RFB No. 2,161/2023 defined key terms such as “controlled transaction” and “related party” and set implementation rules. At the same time, Constitutional Amendment No. 132/2023 and Complementary Law No. 214/2025 established the IBS, CBS and the Selective Tax (IS), taxes that will replace ICMS, ISS, PIS, and COFINS with a dual VAT model, shared between the federal level (CBS) and state and municipal governments (IBS). The replacement will occur gradually, over a transition period ending in 2033.
Among the main features of the new taxes are full non-cumulatively and a broad tax base. Full non-cumulatively aims to reduce distortions and relieve the production chain by ensuring broad credit recovery for taxes paid in previous stages. The broad tax base reflects the wider scope of the new taxes compared to those being replaced, covering the taxation of any goods, services, or rights, including leasing, rental, and other taxable operations. In this scenario, one of the potential effects that taxpayers will need to monitor, in relation to transfer pricing, concerns the impact of the tax reform on prices and, consequently, on companies’ profit margins. Since IBS and CBS will modify the tax burden on transactions, there may be direct effects on costs, pricing policies, and profitability. This may require adjustments to the comparables used in transfer pricing analyses or even benchmarking studies, to ensure that these parameters properly reflect the effects of the tax reform and thus avoid adjustments to the IRPJ and CSLL tax bases.
Colombia
On 1 September, the Colombian Treasury Department proposed legislation changes including changes to international taxation. The proposed changes would limit the deductibility of expenses with low tax jurisdictions.
Czech Republic
On 2 September, the Czech president signed a bill amending the Czech “Act on Top-Up Taxes”. This confirmed the GloBE information return (GIR) deadline, which requires filing 15 months after the end of the reporting period (18 months for the transition year, ending on 30 June 2026 for the 2024 calendar year). Notifications in other jurisdictions and local tax return filings and payments are due within 22 months after the fiscal year-end.
European Union
- On 4 September, the CJEU ruled in the case C-726/23 (SC Arcomet Towercranes SRL) that transfer pricing adjustments relating to the remuneration of intra-group services may be subject to VAT. The transfer pricing adjustment should follow a contract and be calculated in accordance with a TP method recommended by the OECD TP Guidelines.
Additionally, the CJEU ruled that Tax Authorities are not limited to accepting invoices as proof for VAT deduction claims and may require additional documentation.
- On 24 September, the European Commission presented the second pilot of the European Trust and Cooperation Approach (ETACA). The European Commission seeks, through ETACA, to reduce transfer pricing disputes through early, structured collaboration.
Kazakhstan
On 26 September, the Kazakhstani tax authority issued a decree (№ 530) approving and publishing standardised forms and templates related to Mutual Agreement Procedures (MAP). These will apply from 1 January 2026.
Malta
On 2 September, Malta implemented new legislation, introducing an option for companies to opt for a 15% rate on taxable income replacing the rate in section 56(6) of the Act. Entities electing this alternative rate must do so by notice and are bound by this option for at least five years. The resulting tax is considered final and is not eligible for refund or credit.
OECD
- On 4 September, the OECD published an updated list of jurisdictions that have signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) under Pillar Two. The included jurisdictions are Austria, Belgium, Denmark, France, Ireland, Italy, Japan, South Korea, Luxembourg, the Netherlands, New Zealand, Portugal, Slovakia, Spain, Switzerland, and the United Kingdom.
- On 23 September, the OECD published its annual peer review regarding the implementation of Country-by-Country (CbC) reporting standards by 142 jurisdictions. The review concluded continued progress with more jurisdictions adopting legal frameworks and information exchange agreements for CbC reporting.
- On 29 September, the OECD published updated Arbitration Profiles for Australia, Belgium, the Netherlands and New Zealand.
Portugal
On 2 September, Portugal published Ordinance No. 290/2025/1 in the Official Gazette, approving Registration Form 62 and its accompanying instructions for the Portuguese minimum taxation regime under Pillar Two. Each constituent entity located in Portugal and included in the scope of the GloBE Rules must submit Form 62 within nine months after the end of the fiscal year in which the group becomes subject to the GloBE Rules, or within 12 months for the transitional year. Failure to file this form in a timely manner may result in penalties.
Korea
On 18 September, South Korea’s Supreme Court overturned its long-standing precedent regarding the taxation of royalties for patents not registered in Korea. Previously, the Court had held that royalties for such patents did not constitute Korean-source income under the Korea-U.S. Tax Treaty as this income had been linked to the exercise of exclusive legal rights based on the principle of territoriality. The recent ruling shifts this stance, determining that royalties for the use of patented technology in Korea may be subject to Korean tax, irrespective of the patent’s registration status within the country. The key factor is whether the patented technology is implemented or utilised in Korea, rather than whether the patent is registered there.
Senegal
On 17 September, Senegal’s Directorate General of Taxes and Domains, through an official statement, suspended the obligation to file the country-by-country report by companies established in Senegal for the financial years 2023 and 2024.
Switzerland
On 12 September, the Federal Council adopted new legislation, implementing the GloBE information return (GIR). This will enable MNE’s to submit this information centrally in a single jurisdiction. The jurisdictions participating in the exchange of information should then be able to verify the plausibility of the tax calculations of MNE groups within the framework of the minimum tax rate.
United States
On 3 September, the U.S. Court of Appeals ruled on the case “Medtronic, Inc. v. Commissioner, No. 23-3063”. The dispute revolves around the determination of an arm’s length income allocation related to intangible assets. The Court of Appeals reversed the Tax Court’s ruling and sent the case back for further proceedings. It held that the Tax Court erred in rejecting both parties’ proposed transfer pricing approaches, the Comparable Uncontrolled Transaction (CUT) method and the Comparable Profits Method (CPM), and instead employed an undefined, catch-all method. The Court of Appeals directed that the Tax Court has to perform additional fact finding, especially as to whether the selected comparables are in fact comparable and how risk differences should be accounted for, in order to choose the most appropriate method.
Final words
Thank you for taking the time to read this edition of our newsletter. I hope you found the insights and updates valuable. Do you have any questions or need further information? Contact us today to get expert advice on worldwide transfer pricing matters and developments.
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Best regards,
Adriaan van der Heijden
Director at Quantera Global
