Quantera Global Newsletter - November 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

Quantera Global news, developments, and blogs

• We are proud to announce our strategic partnership with?MUSE Strategy, a high-end consulting firm focusing on transfer pricing & operational modelling, international taxation and related business advisory services. The firm is headquartered in Milan, Italy. This partnership combines our strengths in these areas to provide MNEs with tailored, effective transfer pricing solutions.?
• On 12 October, we hosted a webinar together with Shiv Mahalingham, partner of The Cragus Group. The webinar focused on transfer pricing and related topics from a UAE perspective.?
• On 24 October, we published a blog on the technical support we provided in a European Commission project on APAs. The project has now been completed and we look back at a great experience where we were able to share our expertise and knowledge and contribute to the strengthening of the Polish and Slovak APA practices. You can find the blog here.?

Quantera Global specialties

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

• Assisting a client in analysing and documenting whether the Dutch anti-hybrid mismatch rules (ATAD 2) apply to their Dutch business; ?
• Developing a tailor-made Operational Transfer Pricing (OTP) solution for a client that semi-automates work that previously took two weeks from accountants and provides further insight; and ?
• Performing a cash pool analysis for multiple currency cash pools.?

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

QG Academy Webinars

As part of the Quantera Global’s 10th anniversary celebrations, we are delighted to announce that on 30 November we will host a webinar on intercompany financial transactions from a global perspective.

Transfer Pricing attention towards financial transactions has taken off in recent years and has further increased following the release of the OECD Guidance on this topic in February 2020. Attention to and expertise on this topic has grown among tax authorities leading, amongst other things, to more tax audits related to financial transactions.?

Our business partners in Brazil, India, the Netherlands, and the United States will guide you through the most significant developments in this field within their respective region.?

We have also scheduled the following webinars:?

• 14 December on Scandinavia?

For more information or to register for upcoming webinars, please visit our website: https://www.quanteraglobal.com/group-sessions/?

You can watch our previous webinars here.??

News from around the world

Austria?

On 3 October, the Austrian Ministry of Finance published draft legislation regarding the Pillar Two Global minimum tax. Failure to comply with the new legislation can lead to penalties up to €100,000.?

Belgium?

The Belgian Court has ruled in a case concerning the at arm’s length nature of an intercompany loan. The Court re-evaluated the firm’s credit rating by considering the implicit support from the group.??

Brazil?

On 29 September, Brazil’s Federal Revenue published new transfer pricing rules that are more in line with the 2022 OECD guidelines. In addition to the new rules, taxpayers will also be given the option of applying the new rules retroactively in 2023 or phasing in the new system from January 2024.

Cyprus?

On 3 October, the Ministry of Finance of Cyprus published draft legislation on Pillar Two global minimum tax. The law should come into force on 31 December. Regarding the Undertaxed Profits Rule, the law will come into force on 31 December 2024.

European Union?

On 17 October, the European Union adopted a revised list of non-cooperative jurisdictions for tax purposes. Three countries were added to the list and three others were removed from it. Jurisdictions on the list either fail to meet the EU’s criteria or they are subject to further monitoring while they meet their remaining commitments.

Ireland?

On 19 October, a bill was proposed including, amongst others, measures regarding income tax, business tax and property. The bill will be signed into law in December.

OECD?

On 11 October, the OECD published several documents regarding the Multilateral Convention to implement Amount A of Pillar One.??

UAE?

On 23 October, the UAE tax authorities published a new transfer pricing guide. This guide covers the at arm’s length principle as well as transfer pricing documentation. This new guide takes into consideration the OECD transfer pricing guidelines of 2022.