מחירי העברה: פורטוגל- פברואר 2010

The Portuguese Corporate Income Tax (IRC) Code contains regulations on transfer pricing, based on OECD recommendations, together with the adoption of the arm’s length principle.

The transfer pricing regulations, covering methods, issues related to documentation and corresponding adjustments, are contained in Ministerial Order N÷ 1446-C/2001, of 21 December 2001.

Taxpayers with global net profits of more than EUR 3 million in the previous taxable period are required to keep duly organised on the tax file transfer pricing documentation as required by the Ministerial Order.

Since 1 January 2008, taxpayers have the possibility of concluding Advance Pricing Agreements (APAs) with the tax authorities, in order to determine the method that will be used to analyse operations under the transfer pricing provisions.

Taxpayers who are obliged to keep transfer pricing documentation but fail to do so are liable to a penalty of between EUR 500 and EUR 100 000. 

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