Quantera Global Newsletter – March 2023

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.

Quantera Global news, developments, and blogs

• 2023 Pillar 2: We worked with our clients to determine their initial Pillar 2 position.?Click here to see our flyer?on this topic and feel free to contact us for more information to prepare well before 2024.
• On 2 March, we published a blog on comparability analyses. The blog can be found?here
• On 16 February, we hosted our second Quantera Global 10-year anniversary webinar where we discussed key developments in the?Brazilian transfer pricing?landscape. Interested in the recording? Please send an e-mail to?[email protected].
• On 6 February, we published a blog on key developments in the Dutch transfer pricing landscape. The blog can be found?here
• We are hiring! An overview of our vacancies can be found?here.

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

Quantera Global specialties

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

• Supporting a Dutch multinational in determining the most appropriate arm’s length remuneration for the various functions it performs.
• Assisting a Dutch multinational in obtaining Advance certainty from the Dutch Tax Authorities.
• Assisting various multinationals in meeting their transfer pricing documentation requirements.

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

QG Academy Events & Webinars

On Thursday 23 March, we will host the next Quantera Global 10-year anniversary webinar. This webinar will focus on the United Kingdom.

During this webinar the following topics will be discussed:

• HMRC’s metamorphosis in thepast decade;
• The UK’s perspective on EU directives such as ATAD post Brexit and wider supranational efforts;
• The main developments in UK TP you can expect for 2023, including revised transfer pricing documentation requirements

To register for the upcoming webinar, please visit our website?https://www.quanteraglobal.com/group-sessions/.

We have also scheduled the following webinar:

• 5 April: How to grow your business utilizing TP automation

In 2023, we will host several country-specific webinars on a monthly basis. 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 from around the world:

European Union

On 14 February, the Council of the European Union updated its list of non-cooperative jurisdictions for tax purposes by adding the British Virgin Islands, Costa Rica, the Marshall Islands and Russia. This subsequently allows EU Members states to include these countries on its list of non-cooperative jurisdictions for tax purposes under domestic law.

Hong Kong

The financial secretary of Hong Kong presented its 2023-2024 budget to the Legislative Council. The budget includes the introduction of a patent box to boost the R&D. It also includes a provision that would implement the global minimum tax from 2025 onwards.

India

The 2023 Union Budget of India was presented on 1 February. The Budget does not provide a possible framework for the implementation of?Pillar Two, although this was expected.

Japan

On 3 February, the Japanese government submitted a tax reform package. The legislation includes provisions to implement the Income Inclusion Rule of the global minimum tax initiative.

OECD

• On 1 February, the OECD published a Manual on the Handling of Multilateral Mutual Agreement Procedures and Advance Pricing Arrangements. The Manual provides guidance to jurisdictions on the handling and resolving of multilateral MAP or?APA?cases.
• On 2 February, the OECD published technical guidance on the implementation of the global minimum tax. The guidance is intended to assist governments implement the global minimum tax, which will ensure that multinational enterprises are subject to a 15% effective minimum tax rate.

Poland

The Polish government has published a draft bill enacting the DAC7 directive. The directive requires digital platform operators to disclose certain information to their tax authorities.

Qatar

On 2 February, the State of Qatar amended its Income Tax Law. A new definition of the arm’s length principle was introduced to further align it with the OECD definition.

South Africa

On February 22, the South African Finance Minister published the National Budget, including a legislative framework regarding bilateral Advance Pricing Agreements.

Singapore

The government of Singapore has announced that it will implement the global minimum tax rate of 15% from 1 January 2025.

Sweden

The Swedish government has published legislation requiring Swedish multinational groups to publicly disclose information on their income and taxes paid in different countries.

Switzerland

Switzerland has published its safe-harbour interest rates. The rates may be applied on shareholder and?intercompany loans. A deviation from these interest rates is possible as long as it is supported by the arm’s length principle.