Welcome to the Transfer Pricing Method Podcast!
Welcome to the Transfer Pricing Method Podcast by Quantera Global!
Your go-to source for the latest insights and updates on all things related to transfer pricing. Hosted by Adriaan van der Heijden, Managing Director at Quantera Global, this podcast delves into all different kinds of transfer pricing topics, offering expert advice and practical solutions for upcoming changes and challenges in the field.
At Quantera Global, we are honored to be the largest independent advisory firm specializing in transfer pricing. With a robust global network spanning over 50 countries, we’ve earned the trust of more than 400 multinational companies over the past decade.
Join us every month to dive deeper into a new topic of transfer pricing!
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Recent guests:
Gian Luca Nieddu
Gian Luca is an Italian CPA with a strong focus on international taxation transfer pricing and operational modelling. Having worked with multinational enterprises for more than 20 years, Gian Luca has also gained relevant experience in Risk Management projects and international tax controversy including APAs and MAPs.
Gian Luca Nieddu
CEO and founder of MUSE strategy
Mihai Lupu
Mihai Lupu is a Partner of Transfer Pricing Services in Romania. He is a long-lasting and important partner within the Quantera Global network. Mihai has over 15 years of experience in the transfer pricing field and has experience in all types of transfer pricing-related projects.
Mihai Lupu
Partner at Transfer Pricing Services
André Oliveira
André is the Head of the Tax Department of the Brazilian law firm Castro Barros. André is the Secretary General of the Brazilian branch of the International Fiscal Association, IFA. André has strong experience in international taxation, which involves transfer pricing and international restructuring, including negotiation with the Brazilian IRS on relevant Tax issues.
André Oliveira
Senior Tax Partner at Castro Barros
Oliver Treidler
Oliver is a transfer pricing economist and founded TP&C in 2017, providing pragmatic advice on transfer pricing. Oliver frequently publishes articles on transfer pricing issues and has also published two books on transfer pricing. In 2020 he published Transfer Pricing in One Lesson and in 2023 he published the Transfer Pricing Survival Guide. Oliver started his professional career at Deutsche Lufthansa in accounting before luckily strumming into the transfer pricing world in 2008.
Oliver Treidler
CEO & Founder of TP&C
Stevi Frooninckx
Steve is the CEO and co-founder of LocTax, a VC-backed tax tech startup that offers a control centre for global tax operations. Before, Stevie worked in advisory, big four mainly, and the biggest part of his career was in-house at different multinationals, ranging from Fortune 500 players to privately owned companies. Stevie started his career in international and corporate tech, focusing on M&A and real estate, but evolved worked in a true jack of all trades, including TP responsibilities.
Stevi Frooninckx
CEO & Chief Tax Officer at Loctax
Borys Ulanenko
Borys is the founder of Arms Length AI, a tax technology company applying AI to automate complex transfer pricing tasks such as benchmarking, functional analysis, and documentation. He has over a decade of experience across Big four advisory in-house roles at Shell and digital product development.
Borys Ulanenko
Founder & CEO of ArmsLength AI
The latest episodes for you:
#7 Romania’s Tax on Affiliates: A New Era for Intra-Group Services and Royalties
Important update: this is no longer in effect!
The Romanian tax authorities announced that they will revoke the tax on affiliates. This is due to a discussion they had with the OECD commission, in which concerns were brought forward regarding the fact that the application of this new piece of legislation is contrary to the OECD principles and standards
- 00:00: Introduction & Guest Backgrounds
- 00:49: Romania’s “Tax on Affiliates” and the 1% deductibility cap
- 02:57: Scope, thresholds and key changes
- 05:47: Deductibility rules and TP
- 11:12: International context and why a 1% cap is unusually rigid
- 15:59: What MNEs should do now
- 20:45: APAs and mitigations
- 29:48: Summary & Closing Remarks
#6 Transfer Pricing in Transition: How Global Developments and AI Are Shaping the Future of Transfer Pricing
- 00:00: Introduction & Guest Backgrounds
- 01:10: Geopolitical Uncertainty and Its Impact
- 03:05: Operational Transfer Pricing and Customs Duties
- 04:10: COVID-19’s Lasting Effects on TP
- 06:55: Legislative Developments & Data-driven Audits
- 15:11: Technology & AI in Transfer Pricing
- 21:38: The Future of the TP Profession
- 28:32: Summary & Closing Remarks
#5 Germany’s Transfer Pricing Shift: Upcoming Global Implications for Transparency and Compliance
- 0:00: Introduction & Guest Backgrounds
- 01:18: Germany’s latest TP changes
- 03:56: Similar developments across Europe
- 07:32: What are the main focus points on financial transactions in Germany?
- 15:42: Group vs. Standalone Ratings
- 18:23: What’s changed in intermediary financing structures in the Netherlands?
- 20:10: Intangibles: Key Developments
- 21:47: How are German tax authorities applying the DEMPE framework?
- 27:23: Trends in audits and court cases
- 30:13: Summary and Closing Remarks
#4 Operational Transfer Pricing – Mitigate risks and maintain control
- 00:00: Introduction & Guest Backgrounds
- 01:34: What is Operational Transfer Pricing?
- 02:45: Challenges in Operational Transfer Pricing
- 09:10: Benefits of a solid OTP process
- 14:12: Key pitfalls
- 20:23: Responsibility for OTP: ownership and collaboration
- 22:15: Closing Remarks
- 25:57: Summary and Closing Remarks
#3 Brazil’s Adoption of OECD Guidelines: A Tax Revolution
- 00:00: Introduction & Guest Backgrounds
- 01:52: A European View on Brazil’s Tax Reforms
- 05:00: Brazil’s Transfer Pricing Transformation
- 12:45: Challenges for Multinationals
- 22:27: Compliance and Documentation Requirements
- 26:20: The Role of Advanced Pricing Agreements (APAs)
- 31:30: Summary and final remarks and Closing Remarks
#2 Public Country-by-Country Reporting: Dutch & Romanian Perspectives
- 00:00: Introduction & Guest Backgrounds
- 01:07: Overview of country-by-country reporting (CBCR)
- 02:24: Romania’s early adoption of public CBCR
- 12:40: Implementation across Europe
- 17:05: Stakeholders and risks of public CBCR
- 23:50: Penalties and enforcement
- 26:20: Summary and final remarks
#1 Advance Pricing Agreements (APA) in the Netherlands and Italy
- 00:00: Introduction & Guest Backgrounds
- 01:42: Most relevant futures of APA’s
- 08:56: Benefits of an APA
- 10:26: Unilateral, bilateral and multilateral
- 18:58: What to consider before an APA
- 26:17: The cost of an APA
- 29:54: Summary
About the host
Adriaan van der Heijden is a Managing Director at Quantera Global. He has experience in all aspects of Transfer Pricing, from design to defence and documentation. Additionally, Adriaan had the honor to be a board member of the Transfer Pricing section of the Dutch Association of Tax Advisers (NOB).
Contact Adriaan van der Heijden:
a.vanderheijden@quanteraglobal.com