The Transfer Pricing Method

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Welcome to the Quantera Global transfer pricing method podcast! Your go-to source for the latest insights and updates on transfer pricing. Hosted by Adriaan van der Heijden, Director at Quantera Global, this podcast delves into all different topics regarding transfer pricing, offering expert advice and practical solutions for upcoming changes and challenges in the field. Join us every month to explore transfer pricing one episode at a time.

Tập

  1. #7 Romania’s Tax on Affiliates: A New Era for Intra-Group Services and Royalties (See Description!)

    14 THG 1

    #7 Romania’s Tax on Affiliates: A New Era for Intra-Group Services and Royalties (See Description!)

    Important update: this is no longer in effect!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 -------------------------------------------------------------------------------------------------------------------- Romania’s transfer pricing landscape is shifting fast, and a new “tax on affiliates” is changing how multinationals think about intragroup charges, deductibility, and audit exposure. With a 1% deductibility cap in play, tax teams need to understand what’s covered, what’s uncertain, and what actions to take now to stay in control. In this episode of The Transfer Pricing Method, host Adriaan van der Heijden is joined by: 🔹 Mihai Lupu - Partner at TPS Romania 🔹 Rudolf Sinx - Managing Director at Quantera Global Together, they break down the new Romanian measure in practical terms, discuss how it compares internationally, and explore mitigation routes like APAs, documentation strategy, and potential operating model adjustments. Key topics discussed: 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 This episode is packed with real-world insight and practical steps to help you anticipate enforcement, reduce surprises, and make defensible decisions under evolving rules. 🔔 𝐉𝐨𝐢𝐧 𝟐,𝟎𝟎𝟎+ 𝐓𝐚𝐱 𝐚𝐧𝐝 𝐅𝐢𝐧𝐚𝐧𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬 Subscribe to our newsletter for the latest industry insights, trends, and updates. 📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter 🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬 Deepen your expertise with our most recent sessions on key transfer pricing topics. 📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/group-sessions/ 🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧 Schedule a free consultation with our operational transfer pricing experts. 👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/TransferPricingconsultancy@quanteraglobal.com/

    33 phút
  2. #6: Transfer Pricing in Transition: How Global Developments and AI Are Shaping the Future of Transfer Pricing

    04/08/2025

    #6: Transfer Pricing in Transition: How Global Developments and AI Are Shaping the Future of Transfer Pricing

    Global uncertainties, rapid legislative change, and the rise of AI are transforming the transfer pricing landscape. From shifting geopolitics and supply chain disruptions to increasingly data-driven audits and the practical application of new technology, transfer pricing teams face more complexity and opportunity than ever before. In this episode of The Transfer Pricing Method, host Adriaan van der Heijden welcomes: 🔹 Borys Ulanenko – Founder of Arms Length AI 🔹 Maikel Verhoeven – Managing Director at Quantera Global Together, they discuss how international developments, digital innovation, and evolving regulations are reshaping the profession and what you can do to keep pace. Key topics discussed: 0:00 Introduction & Guest Backgrounds 01:10 Geopolitical Uncertainty and Its Impact on Transfer Pricing 03:05 Operational Transfer Pricing and Customs Duties 04:10 Lasting Effects of the COVID-19 Pandemic on TP Models 06:55 Legislative Developments & Data-driven Audits 15:11 Technology, AI, and Their Role in Transfer Pricing 21:38 The Future of the Transfer Pricing Profession 28:32 Summary & Closing Remarks This episode is packed with actionable insights, practical advice, and forward-looking strategies to help you future-proof your transfer pricing operations, whether you are in-house, in advisory, or just starting your career. 🔔 𝐉𝐨𝐢𝐧 𝟐,𝟎𝟎𝟎+ 𝐓𝐚𝐱 𝐚𝐧𝐝 𝐅𝐢𝐧𝐚𝐧𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬 Subscribe to our newsletter for the latest industry insights, trends, and updates. 📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter 🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬 Deepen your expertise with our most recent sessions on key transfer pricing topics. 📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/group-sessions/ 🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧 Schedule a free consultation with our operational transfer pricing experts. 👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/TransferPricingconsultancy@quanteraglobal.com/

    31 phút
  3. #5 Germany’s Transfer Pricing Shift: Upcoming Global Implications for Transparency and Compliance

    28/05/2025

    #5 Germany’s Transfer Pricing Shift: Upcoming Global Implications for Transparency and Compliance

    German transfer pricing legislation is evolving fast, and the implications for multinational companies are profound. From administrative principle updates to heightened scrutiny on financial transactions and intangibles, companies operating in Germany need to be more prepared than ever.    In this episode of The Transfer Pricing Method, host Adriaan van der Heijden is joined by:    🔹 Oliver Treidler – CEO & Founder of TP&C  🔹 Rudolf Sinx – Managing Director at Quantera Global    Together, they unpack Germany’s recent regulatory developments and what they mean in practice for multinationals and their tax teams.  Key topics discussed:  0:00 Introduction & Guest Backgrounds 01:18: How do the new changes influence day-to-day transfer pricing in Germany? 03:56: Are similar developments happening across other European countries? 07:32: What are the main focus points on financial transactions in Germany? 15:42: Group vs. Standalone Ratings: what if countries disagree? 18:23: What has changed in intermediary financing structures in the Netherlands? 20:10: What are the key developments and challenges around intangibles? 21:47: How are German tax authorities applying the DEMPE framework? 27:23: What are the developments in tax audits and court cases 30:13: Summary and Closing Remarks   This episode is packed with real-world lessons, practical tips, and strategic insight to help you mitigate risks and maintain control.  🔔 𝐉𝐨𝐢𝐧 𝟐,𝟎𝟎𝟎+ 𝐓𝐚𝐱 𝐚𝐧𝐝 𝐅𝐢𝐧𝐚𝐧𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬 Subscribe to our newsletter for the latest industry insights, trends, and updates. 📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter 🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬 Deepen your expertise with our most recent sessions on key transfer pricing topics. 📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/group-sessions/ 🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧 Schedule a free consultation with our operational transfer pricing experts. 👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/TransferPricingconsultancy@quanteraglobal.com/

    34 phút
  4. #4 Operational Transfer Pricing - Mitigate risks and maintain control

    27/03/2025

    #4 Operational Transfer Pricing - Mitigate risks and maintain control

    Operational Transfer Pricing (OTP) has become a key driver of control, compliance, and business enablement within multinational organisations. But getting it right requires more than just good intentions. In this episode of The Transfer Pricing Method, host Adriaan van der Heijden is joined by: 🔹 Maikel Verhoeven – Managing Director at Quantera Global 🔹 Stevi Frooninckx – CEO & Co-founder of Loctax Together, they dive into what it takes to build an effective OTP framework - and what can go wrong without one. Key topics discussed: ● 00:00 Introduction & Guest Backgrounds ● 01:34 What is Operational Transfer Pricing (OTP)? ● 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 This episode is packed with real-world lessons, practical tips, and strategic insight to help you mitigate risks and maintain control. 🔔 𝐉𝐨𝐢𝐧 𝟐,𝟎𝟎𝟎+ 𝐓𝐚𝐱 𝐚𝐧𝐝 𝐅𝐢𝐧𝐚𝐧𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬 Subscribe to our newsletter for the latest industry insights, trends, and updates. 📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter 🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬 Deepen your expertise with our most recent sessions on key transfer pricing topics. 📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/group-sessions/ 🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧 Schedule a free consultation with our operational transfer pricing experts. 👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/TransferPricingconsultancy@quanteraglobal.com/

    29 phút
  5. #3: Brazil’s Adoption of OECD Guidelines: A Tax Revolution

    03/02/2025

    #3: Brazil’s Adoption of OECD Guidelines: A Tax Revolution

    Join Quantera Global’s latest podcast episode as experts Emile Monfils and André Oliveira dive into Brazil’s Adoption of OECD Guidelines. Learn about the challenges multinationals face, the impact on local compliance, and how Advanced Pricing Agreements (APAs) are shaping transfer pricing in both Brazil and Europe. 🔔 𝐉𝐨𝐢𝐧 𝟐,𝟎𝟎𝟎+ 𝐓𝐚𝐱 𝐚𝐧𝐝 𝐅𝐢𝐧𝐚𝐧𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬 Subscribe to our newsletter for the latest industry insights, trends, and updates. 📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter 🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬 Deepen your expertise with our most recent sessions on key transfer pricing topics. 📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/group-sessions/ 🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧 Schedule a free consultation with our operational transfer pricing experts. 👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/TransferPricingconsultancy@quanteraglobal.com/

    35 phút
  6. #2 Public Country-by-Country Reporting: Dutch & Romanian Perspectives

    03/12/2024

    #2 Public Country-by-Country Reporting: Dutch & Romanian Perspectives

    Join Quantera Global’s latest podcast episode as experts Rudolf Sinx and Mihai Lupu dive into the complexities of public country-by-country reporting (CBCR). Learn about Romania’s pioneering role in implementing public CBCR, its impact across Europe, and the risks, opportunities, and penalties involved for multinational companies. 🔔 𝐉𝐨𝐢𝐧 𝟐,𝟎𝟎𝟎+ 𝐓𝐚𝐱 𝐚𝐧𝐝 𝐅𝐢𝐧𝐚𝐧𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬 Subscribe to our newsletter for the latest industry insights, trends, and updates. 📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter 🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬 Deepen your expertise with our most recent sessions on key transfer pricing topics. 📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/group-sessions/ 🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧 Schedule a free consultation with our operational transfer pricing experts. 👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/TransferPricingconsultancy@quanteraglobal.com/

    32 phút
  7. #1 Advance pricing agreements (APA) in the Netherlands and Italy

    17/09/2024

    #1 Advance pricing agreements (APA) in the Netherlands and Italy

    Join Quantera Global's first webinar on APAs in the Netherlands and Italy with experts Richard Slimmen and Gian Luca Nieddu. Gain insights into APA features, benefits, and critical considerations from professionals with decades of experience in international taxation and transfer pricing. 🔔 𝐉𝐨𝐢𝐧 𝟐,𝟎𝟎𝟎+ 𝐓𝐚𝐱 𝐚𝐧𝐝 𝐅𝐢𝐧𝐚𝐧𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬 Subscribe to our newsletter for the latest industry insights, trends, and updates. 📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter 🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬 Deepen your expertise with our most recent sessions on key transfer pricing topics. 📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/group-sessions/ 🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧 Schedule a free consultation with our operational transfer pricing experts. 👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/TransferPricingconsultancy@quanteraglobal.com/

    35 phút
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Giới Thiệu

Welcome to the Quantera Global transfer pricing method podcast! Your go-to source for the latest insights and updates on transfer pricing. Hosted by Adriaan van der Heijden, Director at Quantera Global, this podcast delves into all different topics regarding transfer pricing, offering expert advice and practical solutions for upcoming changes and challenges in the field. Join us every month to explore transfer pricing one episode at a time.

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    Quantera Global
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    2025 - 2026
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