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    Quantera Global Newsletter – September 2021

    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.

    Quantera Global news, developments, and blogs:

    • Expert Guides: “Guide to the World’s Leading Transfer Pricing Advisers”

    We are very honored that Quantera Global has been ranked as one of the leading Dutch transfer pricing specialists in the recent edition of Expert Guide’s “Guide to the World’s Leading Transfer Pricing Advisers”.

    • Quantera Global specialties

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

    • Supported multiple clients in transfer pricing audits.
    • Concluded an Advance Pricing Agreement (APA) with the Belgian Tax Authorities for a toll manufacturer.
    • Set-up the full Transfer Pricing policy and documentation for a SME.

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

    QG Academy Webinars

    Last year we started hosting free-of-charge webinars on a variety of Transfer Pricing topics and we are continuing these webinars in 2021. We currently have the following webinars scheduled:

    • 9 September: Transfer Pricing Risk Management: APAs & MAPs

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

    You can watch our previous webinars here.

    News around the world:

    • Australia

    On 12 August, the Australian tax office released a discussion paper on the common tax consequences and challenges of the IBOR transition. As part of a transition to other ‘risk-free rates’, reforms are underway with respect to common interest rate benchmarks, including the London Inter-Bank Offered Rate (LIBOR), which is expected to be partially eliminated by the end of the year.

    For more information on the IBOR reform and its transfer pricing implications, we refer to our blog here.

    • China

    China’s state tax has designed a simplified procedure for APA requests that will come into effect on 1 September 2021.

    • Dominican Republic

    On 3 August, the Dominican Republic announced a public consultation on country-by-country reporting.

    • Hong Kong

    On 29 July 2021, the Inland Revenue Department (IRD) issued guidelines for the examination of certain tax issues related to the coronavirus pandemic. This document sets out the tax issues related to, among others, permanent establishments (PEs) and tax residence of companies.

    • India

    On 10 August 2021, the Central Board of Direct Taxes (CBDT) issued a notice – CBD Notice – prescribing a new rule. When there is an increase in profit due to an APA adjustment or secondary adjustments, the rule can be used to calculate tax relief.

    • Mexico

    The Mexican tax authorities have published a list of projected effective tax rates for various economic activities and industries for the fiscal years 2016 to 2019.

    • Morocco

    In a transfer pricing audit of a global player in the rapidly changing consumer goods industry, the Moroccan tax authorities issued a record-breaking tax adjustment of USD 110 million. The tax authorities rejected the transfer pricing method applied by the company to its flows of goods and services.

    • The Netherlands
    • The Decree on rulings with an international character of 19 June 2019 has been amended. This is an addition resulting from legislation that recently came into force. As a result of the amendments, preliminary consultations on hybrid mismatches and the 2021 Withholding Tax Act can also be handled according to the procedure described in this Decree.
    • The Zeeland-West-Brabant District Court ruled that loans provided by X bv to Q were non-commercial. The inspector argued that an independent third party would not have provided the same loans with the same terms and conditions to third parties. In this respect it is important that the loans were not laid down in intercompany agreements.
    • OECD

    The OECD released the third edition of its annual publication on corporate tax statistics on 29 July 2021, along with an updated database. According to the OECD, the database is intended to increase the quality and scope of data available for the analysis of base erosion and profit shifting (BEPS) and to assist in the study of corporate tax policy.

    • Singapore

    On 10 August, the Inland Revenue Authority of Singapore released the sixth edition of its e-tax guide on transfer pricing. A new chapter has been added on expense contribution plans, expanded financial transaction guidelines and other revisions.

    • United Kingdom

    The UK has announced its intention to introduce new disclosure rules from 1 April 2022.