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The laws surrounding transfer pricing are becoming ever more complex, as tax affairs of multinational companies are facing scrutiny from media, regulators and the public
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Banking Holding banking to account: the real diversity and inclusion pictureWe explore how the banking sector can continue to attract, retain and nurture women to build a more diverse and inclusive future.
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Sustainability From voluntary to mandatory ESG: How banks can future-proof their operationsAs we move from voluntary ESG initiatives to mandatory legislation, we explore what the banking sector needs to prioritise.
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growthiQ Steering your company to long-term successHistory has something important to tell us about the difficulties of steering a business to long-term success – through seismic shifts in technology, consumer demands and product development. With that in mind it’s unsurprising that over half the world’s largest companies in the early 1900s had shut their doors by the late 1990s. Some, however, have endured.
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Industries European Real Estate PodcastJessica Patel, Tax Partner at Grant Thornton UK speaks with tax partners and directors across the network to share their insights on the real estate market and some of the challenges.
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Cybersecurity One size fits nothingTechnology companies must adopt a new approach to digital risk: those that successfully develop a reputation for digital trust by demonstrating an unwavering commitment to cyber security and data privacy will be able to carve out a competitive advantage.
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Trade in transition
A shifting global trade landscape is contributing to rising uncertainty, but could it also unlock new opportunites for adaptable mid-market businesses while larger companies opt to wait and see?
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International business: Mid-market growth and expansion
The mid-market looks to international business opportunities for growth.
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Top five constraints to international business in the mid-market
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Brand and international marketing – breaking global barriers
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The key to international business: Investing in people
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Building resilience in international business
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Example Financial Statements
The 2025 Interim Financial Statements provide general guidance on preparing interim financial statements in accordance with IFRS Accounting Standards.
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IFRS 8
Our ‘Insights into IFRS 8’ series considers some key implementation issues and includes interpretational guidance in certain problematic areas.
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IFRS 16
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IAS 36
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IFRS 17
Explaining the key features of the Standard and providing insights into its application and impact.
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Pillar 2
Key updates and support for the global implementation of Pillar 2.
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Global expatriate tax guide
Growing businesses that send their greatest assets – their people – overseas to work can face certain tax burdens, our global guide highlights the common tax rates and issues.
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International indirect tax guide
Navigating the global VAT, GST and sales tax landscape.
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Global transfer pricing guide
Helping you easily find everything you need to know about the rules and regulations regarding transfer pricing and Country by Country reporting for every country you do business with.
Please click on each section to expand further:
- Portugal’s transfer pricing (TP) legislation is part of the Corporate Income Tax Law and is based on the arm’s length principle as per Article 9 of the OECD Model Tax Convention on Income and Capital, i.e. it follows the OECD Guidelines.
- TP rules apply to Portuguese taxpayers, including local branches of foreign companies and is up to the taxpayer to confirm its transfer pricing meets the standard or to adjust its tax return accordingly.
- The filing of transfer pricing documentation is generally not mandatory except for large taxpayers, but because of the self-assessment regime, transfer pricing analysis and documentation is required to help protect against penalties. If the Tax Authorities request transfer pricing documentation, the taxpayer would typically have a pre-defined deadline in which to respond.
- The OECD’s Master File and Local File concept is regarded as best practice. In addition, for larger groups (over €750m) Portugal has implemented CbCR (Country by Country Reporting).
- Portuguese transfer pricing rules follow the OECD Guidelines. The Guidelines, updated in July 2017, should be used for interpretation of the arm’s length principle.
- Portuguese Tax Authorities’ have several binding rulings, instructions, and general guidance on its view of transfer pricing matters, and much of this content is publicly available.
- The most appropriate pricing method should be selected on a transaction by transaction basis, providing the most reliable measure of an arm’s length result in each case. The current OECD methods, namely the comparable uncontrolled price, resale price, cost plus, transactional net margin, and profit split methods are all accepted but the method used must be in line with the functional and risk profile of the entity. Other methods can also be used if justifiable and appropriate.
- There is no priority among the acceptable methods as long as the result is at arm’s length.. In practice, however, a ‘natural hierarchy’ may be said to favour the comparable uncontrolled price method.
- Portugal has a self-assessment regime, where the onus is on the taxpayer to ensure that transfer pricing regulations are adhered to. Taxpayers who have reached, in the period to which the obligation refers, a total annual income of less than € 10,000,000 are exempt from preparing and organizing the transfer pricing documentation.
- Even taxable persons who register a higher total annual amount of income are exempt from preparing the transfer pricing documentation for related operations whose value in the period does not exceed € 100,000 per counterparty and, as a whole, € 500,000, considering the respective market value.
- Portuguese corporate income taxpayers need to specify annually in their annual tax returns whether they have been involved in related party transactions. The specific transaction amounts need to be detailed in the corporate income tax return.
- Portugal accepts the OECD transfer pricing documentation model based on the Master File and Local File (BEPS Action 13) approach. This approach is considered best practice.
- Lack of carefully prepared documentation will generally result in fines, whether or not there are adjustments to be made.
- Portugal has also introduced CbCR (Country by Country Reporting) regulations which are effective for fiscal years starting on or after 1 January 2016 for groups with revenues over €750m.
- Any documentation should be prepared in Portuguese (preferable) or English.
- Typically, there are four types of documentation that should be kept: primary accounting records, tax adjustment records, records of transactions with associated parties and documentation demonstrating the arm’s length result.
- Although the Master and Local file structure is best practice and should help with penalty protection, the current documentation requirements are not prescriptive. Tax authorities’ view is that transfer pricing documentation should usually include a background to the company, a group structure, an outline of the key intercompany transactions under analysis, an analysis of the key functions, assets and risks of the company, an industry analysis and an economic analysis including supporting evidence such as comparables, if required. The key is that it explains the value driving activities and the management of risk in the group and shows that the policies are at arm’s length.
- Transfer pricing documentation must be preserved, as all tax and accounting documentation, for a period of 10 (although the statute of limitation is generically of 4 years).
- High risk business models include commissionaire and toll manufacturing.
- Limited risk distributor and contract services/ contract R&D arrangements could also potentially be affected, especially where significant people functions are in Portugal.
- Persistent losses in a “low risk” entity.
- Licensing payments to low tax jurisdictions.
- Business restructurings, or changes in TP model, can also trigger a challenge - however, if the previous TP method no longer appears the most appropriate, it should always be reviewed.
- The main penalty specifically defined for transfer pricing is that related to the non-compliance with the obligation to possess a transfer pricing file. This fine varies between €1,000 and €10,000.
- Penalties may also be applicable for late or no payment of tax due (in this case because of manipulation of transfer prices). These penalties vary between 30% and 100% of tax due. In addition, a 4% compensatory interest rate exists.
- Non-compliance with CbCR and notification requirements can draw penalties ranging also between €1,000 and €10,000. Daily penalties may also apply where information is consistently not provided.
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Tax Authorities will expect to see that a search for potential internal comparables has taken place before defaulting to an external database search for comparables.
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Note that where databases are used, contrary to popular understanding, there is no specific requirement that the interquartile range be used (however, it will often be calculated as a means to eliminate outliers, given that incomplete information will always be an issue in external database searches).
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Unfortunately, the Tax Authorities sometimes use their own comparables. There are also no published TP “safe harbours” and the key is the facts and circumstances of the specific case.
- Advanced Pricing Agreements (APAs) are written agreements between a business and the Tax Authorities to govern the appropriate transfer pricing method for a forward-looking period. There are very few of them.
- Portugal has an extensive treaty network, and the Mutual Agreement Procedure (MAP) will often be available when double tax occurs.
- There are usually no “secondary adjustments” or recharacterisation sought where a TP adjustment is made, but interest and penalties may be applied.
- Transfer pricing rules apply to all companies that engage in related party transactions. However taxpayers who have reached, in the period to which the obligation refers, a total annual income of less than € 10,000,000 are exempt from preparing and organizing the transfer pricing documentation.
- Even taxable persons who register a higher total annual amount of income are exempt from preparing the transfer pricing documentation for related operations whose value in the period does not exceed € 100,000 per counterparty and, as a whole, € 500,000, considering the respective market value.
For further information on transfer pricing in Portugal please contact:
Joaquim Mendes |