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Transfer Pricing

We develop innovative and tax-efficient business strategies.

Get to know more about our tax services

Documentation and compliance requirements

How can we help?

  • Transfer Pricing documentation “health checks”.
  • Documenting and customize Transfer Pricing policies. 
  • Technical reports to support pricing methodologies.
  • Permanent Establishment (PE) and the PE remuneration.
  • Defense Files regarding unusual operations.
  • Country by Country Report (CbCR) and CbCR notification.
  • Reportable mechanisms under DAC 6.
  • Reportable transactions by Listed Companies.
  • Appendix H of the IES Form.
  • Other compliance requirements in countries where the business/Company operates.

Value chain analysis and transformation

How can we help?

  • Value Chain diagnosis and profit allocation.
  • Value Chain restructurings / reorganizations.
  • Design, development and implemention of efficient Transfer Pricing
  • strategies aligned with the value chain.
  • Design of pricing strategies.
  • Preparation for expected changes at the OECD level regarding the “Digital Economy”.
  • Value Chain Transformation to align tax strategies with business models, in line with BEPS.
  • Holistics and reliable reports to demonstrate the opportunities and risks associated with ESG to create value for the Company, stakeholders and society.

Litigation and Advance Pricing Agreements (APAs)

How can we help?

  • Monitoring national and transnacional tax audits regarding Transfer Pricing matters, including corresponding adjustments and Mutual Agreement Procedures (MAPs).
  • Identify red flags from a TP perspective in the business model.
  • Analysis of available information to support terms and condition.
  • Supporting the preparation, application, negociation and implementation of unilateral / bilateral / multilateral APAs.

Technology

How can we help?

  • Preparation and organization of a solid and coordinated Transfer Pricing documentation using tools developed internally by PwC (for example: Global Coordinated Documentation™).
  • Process of Transfer Pricing analysis and technology tools (for example: Alteryx, Power BI, among others) that allow the accelaration of the tax area digital transformation.
  • Optimization of applied time to certain tasks and value-added solutions for data collection, use and processing.

Want to know more?

If your business is related to the following industries, click below.

Banking and Capital Markets Our services in the banking and capital markets sector Insurance Our services in the insurance sector

Real Estate and Asset Management Our services in the real estate sector

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Leendert Verschoor

Leendert Verschoor

Tax Partner – Transfer Pricing, PwC Portugal

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