Strategizing Multinational Tax Risks

Portugal has introduced new transfer pricing rules, including the ability to request a unilateral APA, absent a tax treaty between Portugal and the other jurisdiction.  KPMG has provided a concise summary for these changes:

http://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/taxnewsflash/Pages/2014-1/portugal-transfer-pricing-law-changes-allow-more-unilateral-apa.aspx

Multinationals should consider this new provision to obtain additional certainty re: Portugal’s application of transfer pricing rules.  Recognizing that a unilateral APA does not eliminate the risk of double taxation, this opportunity should be reviewed within the context of the global tax risk framework.