The Transfer Pricing Method
The Transfer Pricing Method
Podcast Description
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.
Podcast Insights
Content Themes
The podcast focuses on key topics related to transfer pricing, including OECD guidelines, country-by-country reporting, and advanced pricing agreements (APAs). For instance, one episode discusses Brazil's adoption of OECD guidelines and the implications for multinationals, while another explores the intricacies of public country-by-country reporting through the perspectives of Dutch and Romanian experts.
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.
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.
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