Strategizing International Tax Best Practices – by Keith Brockman

Posts tagged ‘Portugal transfer pricing’

Portugal: Unilateral APA opportunities

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:

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.


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