Managing Partner
On 13 May 2026, the Court of Justice of the European Union (CJEU) released its judgment in the Stellantis Portugal case. The case addresses a topic that has been debated for years within multinational groups, transfer pricing teams, and indirect tax specialists alike: Can a transfer pricing adjustment trigger VAT? At first sight, this may […]
This guide explains year-end adjustments (YEAs) in plain language: what they are, when to use them, what to consider and what to avoid. What is a year-end adjustment?   A year-end adjustment (YEA), sometimes called a compensating adjustment, is a correction to intercompany prices or margins to bring a tested party within an agreed arm’s length […]
In a recent episode of The Transfer Pricing Method, host Adriaan van der Heijden sat down with Borys Ulanenko (Arms Length AI) and Maikel Verhoeven (Quantera Global) to discuss how technology, global tax reform, and shifting geopolitics are reshaping transfer pricing. Below are the key highlights and practical takeaways from their conversation, tailored for tax and […]
In recent years, tax authorities globally have intensified their focus on transfer pricing (TP) compliance – not solely through traditional audits, but increasingly via comprehensive transfer pricing forms. These structured disclosures, which require taxpayers to report detailed information on intercompany transactions, have become a critical tool enabling tax administrations to conduct data analysis and to […]
Operational Transfer Pricing (OTP) has evolved from being an afterthought to a critical function within multinational enterprises (MNEs). The effectiveness of OTP determines not only regulatory compliance but also financial accuracy, tax efficiency, and overall business stability.  In a recent episode of The Transfer Pricing Method podcast, Maikel Verhoeven, Managing Director of Quantera Global, and Stevi Frooninckx, […]
The Dutch State Secretary for Finance just released important guidance on OECD Pillar 1 Amount B. On 4 December 2024, the Dutch State Secretary for Finance released a Decree in which the consequences of OECD Pillar 1 Amount B for Dutch tax purposes are mentioned. The Decree enters into force on 1 January 2025. OECD […]
As a Chief Revenue Officer (CRO), your role encompasses overseeing all revenue-generating functions within your organization. While you may be focused on sales strategies, customer acquisition, and revenue growth, it’s crucial to understand how transfer pricing can significantly impact your responsibilities and the overall financial performance of your company. The intersection of transfer pricing and sales Transfer pricing, which determines the pricing of goods or services […]
Legal form and economic substance are ideally aligned with each other. If this is not the case, as has historically been the case in some aggressive tax structures, this begs the question what prevails. In this blog we will explain these concepts in more detail and how to deal with this if you would like […]
Understanding the distribution of profits among different entities within a company is crucial. This is particularly important when entities are conducting routine sales but maintain a group margin below 4%. Limited risk distributors, often remunerated with a net operating profit margin of 2-3%, play a key role in this dynamic. However, does this allocation make […]
Managing Director
