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

Many multinationals face documentation backlogs, inconsistent positions across entities, and practical difficulties in implementing policies that look robust on paper but are difficult to apply in reality.📢 In this episode, host Adriaan van der Heijden is joined by:🔹 Mariia Aspidova - Group Tax Director at ExpondoTogether, they discuss:✅ Why transfer pricing backlogs are still common when stepping into a multinational environment.✅ How to assess and rebuild documentation based on real operational substance.✅ The importance of consistency across jurisdictions and documentation sets.✅ How to design transfer pricing policies that can actually be implemented.✅ What audit readiness requires beyond local files and benchmark studies.• 00:00: Introduction & Guest Background• 00:55: TP backlogs when joining a multinational• 01:58: Advice to advisors: go beyond the TP policy• 03:55: How to approach a TP documentation backlog• 06:50: Consistency across TP documentation (local files)• 09:41: Moving from legacy TP policy to a robust framework• 12:11: Dealing with inconsistent TP policies over time• 15:24: From policy to implementation: bridging the gap in practice• 18:05: Stakeholder management in transfer pricing• 20:03: What really matters in audits• 22:30: Transfer pricing in M&A: from late involvement to early impact• 25:02: Summary & Key takeaways🔔 𝐉𝐨𝐢𝐧 𝟐,𝟎𝟎𝟎+ 𝐓𝐚𝐱 𝐚𝐧𝐝 𝐅𝐢𝐧𝐚𝐧𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬Subscribe to our newsletter for the latest industry insights, trends, and updates.📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬Deepen your expertise with our most recent sessions on key transfer pricing topics.📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/webinars-and-events/🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧Schedule a free consultation with our operational transfer pricing experts.👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/[email protected]/

Transfer pricing controversy is rarely won on theory alone. In practice, outcomes are shaped by preparation, evidence, and the ability to explain a consistent story under pressure.In this episode of The Transfer Pricing Method, host Adriaan van der Heijden is joined by:Katrine Ernest Haunstrup, Country Leader at Censio TaxEmile Monfils, Partner at Quantera GlobalTogether, they break down what really drives transfer pricing audits today, what “audit-ready” documentation looks like in practice, and how to manage the first steps of an audit without creating unnecessary risk.You will learn: Why TP audits start today, and what tax authorities look at first  How to move from “we have documentation” to “we are in control”  What makes documentation truly audit-ready Why data and evidence often become the decisive factor  How to respond when the tax authority has a point  How to think about audit strategy early, including escalation and double taxation considerations Prefer reading? The blog summarising this episode is available here.Timestamps00:00 Introduction & Guest Backgrounds 01:17 Why TP audits start today (data visibility and inconsistencies) 03:55 Typical audit triggers (financial outcomes and documentation risk signals) 04:55 Prevention and the shift from “tell me” to “show me” 06:50 Audit readiness starts before documentation (policies, processes, controls) 09:35 Audit-ready TP documentation: approach and structure 12:41 What makes transfer pricing documentation audit-ready? 17:49 Evidence and data: can you actually prove your position? 20:10 Practical tips for audit readiness (what to do in practice) 23:30 What to do when the tax authority has a point 27:45 Summary & Closing Remarks🔔 𝐉𝐨𝐢𝐧 𝟐,𝟎𝟎𝟎+ 𝐓𝐚𝐱 𝐚𝐧𝐝 𝐅𝐢𝐧𝐚𝐧𝐜𝐞 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬Subscribe to our newsletter for the latest industry insights, trends, and updates.📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬Deepen your expertise with our most recent sessions on key transfer pricing topics.📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/webinars-and-events/🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧Schedule a free consultation with our operational transfer pricing experts.👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/[email protected]/

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 GlobalTogether, 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 Backgrounds00:49: Romania’s “Tax on Affiliates” and the 1% deductibility cap02:57: Scope, thresholds and key changes05:47: Deductibility rules and TP11:12: International context and why a 1% cap is unusually rigid15:59: What MNEs should do now20:45: APAs and mitigations29:48: Summary & Closing RemarksThis 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 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬Subscribe to our newsletter for the latest industry insights, trends, and updates.📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬Deepen your expertise with our most recent sessions on key transfer pricing topics.📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/webinars-and-events/🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧Schedule a free consultation with our operational transfer pricing experts.👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/[email protected]/

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 GlobalTogether, 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 Backgrounds01:10 Geopolitical Uncertainty and Its Impact on Transfer Pricing03:05 Operational Transfer Pricing and Customs Duties04:10 Lasting Effects of the COVID-19 Pandemic on TP Models06:55 Legislative Developments & Data-driven Audits15:11 Technology, AI, and Their Role in Transfer Pricing21:38 The Future of the Transfer Pricing Profession28:32 Summary & Closing RemarksThis 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 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬Subscribe to our newsletter for the latest industry insights, trends, and updates.📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬Deepen your expertise with our most recent sessions on key transfer pricing topics.📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/webinars-and-events/🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧Schedule a free consultation with our operational transfer pricing experts.👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/[email protected]/

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 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬Subscribe to our newsletter for the latest industry insights, trends, and updates.📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬Deepen your expertise with our most recent sessions on key transfer pricing topics.📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/webinars-and-events/🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧Schedule a free consultation with our operational transfer pricing experts.👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/[email protected]/

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 LoctaxTogether, 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 SummaryThis 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 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬Subscribe to our newsletter for the latest industry insights, trends, and updates.📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬Deepen your expertise with our most recent sessions on key transfer pricing topics.📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/webinars-and-events/🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧Schedule a free consultation with our operational transfer pricing experts.👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/[email protected]/

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 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬Subscribe to our newsletter for the latest industry insights, trends, and updates.📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬Deepen your expertise with our most recent sessions on key transfer pricing topics.📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/webinars-and-events/🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧Schedule a free consultation with our operational transfer pricing experts.👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/[email protected]/

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 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬Subscribe to our newsletter for the latest industry insights, trends, and updates.📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬Deepen your expertise with our most recent sessions on key transfer pricing topics.📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/webinars-and-events/🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧Schedule a free consultation with our operational transfer pricing experts.👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/[email protected]/

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 𝐩𝐫𝐨𝐟𝐞𝐬𝐬𝐢𝐨𝐧𝐚𝐥𝐬Subscribe to our newsletter for the latest industry insights, trends, and updates.📩 𝐒𝐮𝐛𝐬𝐜𝐫𝐢𝐛𝐞 𝐧𝐨𝐰: https://www.quanteraglobal.com/newsletter🎥 𝐖𝐚𝐭𝐜𝐡 𝐨𝐮𝐫 𝐰𝐞𝐛𝐢𝐧𝐚𝐫𝐬Deepen your expertise with our most recent sessions on key transfer pricing topics.📚 𝐕𝐢𝐞𝐰 𝐡𝐞𝐫𝐞: https://www.quanteraglobal.com/webinars-and-events/🔗 𝐁𝐨𝐨𝐤 𝐚 𝐒𝐭𝐫𝐚𝐭𝐞𝐠𝐢𝐜 𝐒𝐞𝐬𝐬𝐢𝐨𝐧Schedule a free consultation with our operational transfer pricing experts.👉𝐒𝐜𝐡𝐞𝐝𝐮𝐥𝐞 𝐡𝐞𝐫𝐞: https://outlook.office365.com/book/[email protected]/