The Transfer Pricing Method

#8 Transfer Pricing Controversy Management: Audit Readiness and Risk Reduction

Tue, 14 Apr 2026 07:00:00 +0200

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 Tax
Emile Monfils, Partner at Quantera Global

Together, 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.

Timestamps

00:00 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

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

Wed, 14 Jan 2026 14:00:00 +0100

Important update: this is no longer in effect!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
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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.

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

Mon, 04 Aug 2025 14:00:00 +0200

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.

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

Wed, 28 May 2025 17:00:00 +0200

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.

#4 Operational Transfer Pricing - Mitigate risks and maintain control

Thu, 27 Mar 2025 14:00:00 +0100

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.

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

Mon, 03 Feb 2025 13:00:00 +0100

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.

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

Tue, 03 Dec 2024 16:53:27 +0100

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.

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

Tue, 17 Sep 2024 11:08:53 +0200

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.