Quantera Global Newsletter – September 2022 Schedule a call

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    Quantera Global Newsletter – September 2022

    Quantera Global news, developments, and blogs

    Quantera Global news, developments, and blogs

    • On 1 September, Quantera Global organised the webinar ‘’Brazil Transfer Pricing’’. Together with Bocater, the latest developments on Brazilian tax and transfer pricing were discussed. The recording of the webinar can be found here.
    • In addition to this webinar, Quantera Global and Bocater also organised a Master Minds Session on 1 September, where tax professionals shared their knowledge and experiences on Brazil transfer pricing & opportunities.
    • On 11 August, Quantera Global published a blog containing the four key trends from the Dutch Transfer Pricing decree that will impact business.
    • Quantera Global is hiring! An overview of our transfer pricing vacancies.

    Quantera Global specialties

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

    • We assisted one of our clients in obtaining advanced certainty from the local tax authorities regarding their applied transfer pricing policy.
    • We drafted an intercompany loan pricing grid with different variables to allow an MNE to set its intercompany interest rates.

    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:

    Australia announced a consultation with multiple proposals on 5 August. The proposals relate to tax transparency and the taxation of MNEs and include increased public reporting on country-by-country basis. Comments could be submitted until 2 September.

    The Canadian Department of Finance published draft legislation for public comments on 9 August. Comments can be submitted until 30 September. The draft legislation deals with the implementation of remaining tax measures of the 2022 federal budget.

    Hong Kong
    Hong Kong has announced it will postpone the implementation of the Pillar Two rules of the OECD. The implementation was scheduled for 2023 but will be postponed until at least 2024.

    The Irish Revenue published guidance on their Digital Services Tax on 5 August.

    In August, Malaysia held a public consultation on the implementation of the GloBE Rules under Pillar Two. Malaysia intents to implement the GloBE rules as of 2023.

    On 25 August, the OECD published the comments on the public consultation launched on 11 July. The comments received relate to the Progress Report on Amount A of Pillar One.

    On 17 August, the Swiss Federal Council published a public consultation that runs until 17 November. The public consultation concerns the material aspects of the GloBE rules during the transition phase.

    United States

    • The Inflation Reduction Act was signed into law on 16 August. The Act includes a 15% corporate alternative minimum tax for companies that report over USD 1 billion in profits to shareholders, based on book income. The Act will apply to tax years beginning after 31 December 2022.
    • On 18 August, the US tax court issued an opinion on the transfer pricing method to be applied with respect to intercompany licenses for IP required for the manufacture of certain medical devices and leads.

    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.