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Portugal

25 July 2019

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Portugal Amends Transfer Pricing Rules

Portugal's Parliament reportedly approved Law No. 180/2019 on 19 July 2019, which includes amendments to the country's transfer pricing rules. Key changes include:

  • the removal of the hierarchy in selecting the transfer pricing method, and taxpayers will be allowed to apply other methods in cases where the standard methods would not provide reliable results;
  • the expansion of the annual transfer pricing reporting requirements to include the submission of transfer pricing documentation by large taxpayers by the 15th day of the seventh month following the close of the tax year
  • the extension of penalties for failing to submit transfer pricing documentation and CbC reports to also apply for CbC notifications, which include penalties of EUR 1,000 to EUR 20,000 plus 5% per day of delay; and
  • an increase in the maximum validity period of advance pricing agreements (APAs) from three years to four years, as well as related provisions for the exchange of information on APAs with other jurisdictions.

The amendments will apply from 1 October 2019. Further details will be published once available.

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