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After 20 years since the first publication of Transfer Pricing regulations in Portugal (December 21, 2001), in 2021 the legislation was revised, bringing Portuguese legislation closer to international practice in this area, particularly concerning the OECD's BEPS (Base Erosion and Profit Shifting) program.
The increasing internationalisation of business, the complexity of multinational groups, as well as the heightened scrutiny of Tax Authorities regarding intra-group transactions, has made transfer pricing one of the major causes for significant tax contingencies.
Our Transfer Pricing team comprises specialists well positioned to advise you on the planning, implementation, documentation e defense of transfer pricing policies aligned with your financial, operational and tax business goals.
How can we help?
- Transfer pricing documentation health checks;
- Documentation and justification of customised transfer pricing policies;
- Technical files to support a pricing methodology;
- Permanent establishments (PE) and their remuneration;
- Defense files to support a particular operation;
- Country by Country Report and respective notifications;
- Reportable transactions under DAC 6;
- Reportable transactions by Public Companies;
- Relevant Annexes to IES; and
- Reporting obligations in other jurisdictions where your business operates.
How can we help?
- Diagnosis of the supply chain and income allocation;
- Value chain reestructuring and reorganisation;
- Designing, developing and implementing transfer pricing efficient strategies, aligned with the value chain;
- Pricing strategies definition;
- Preparing the predicted developments in the Digital Economy in terms of OECD;
- Value chain transformation to aligne the tax strategies with business models, according to BEPS; and,
- Holistic and reliable reports which demonstrate the handling of opportunities and risks related to ESG, a way of creating value to the company, to their stakeholders and to the society.
How can we help?
- Assistance with tax audits, both national and international, including correlative adjustments and Mutual Agreement Procedures;
- Identification of risky operations and their justification;
- Use and treatment of the information available to support the terms and conditions applied; and,
- Provide assistance in the preparation, request, negotiation and implementation of unilateral, bilateral or multilateral Advance Pricing Agreements (APAs).
How can we help?
- Organize and develop transfer pricing documentation with a robust and coordinated approach through our internal Global Coordinated Documentation™ framework;
- Analysis of transfer pricing procedures and technology tools application (for example: Alteryx, Power BI, among others) to accelerate the digitalization process in the tax area; and,
- Optimize the time spent in specifc tasks and added value solutions to data gathering, data usage and data processing.
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