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transfer pricing


According to the Portuguese transfer pricing rules, which follow the OECD’s guidelines on transfer pricing, operations between related parties must always be transacted at full market price.

In the context of transfer pricing regulation, operations between an entity residing in Portugal and another entity residing in a territory on Portugal’s list of tax havens must be considered to be operations between related parties, even if no shareholding or control relationship exists between the two parties.

Only transacting entities with net sales and other income greater than EUR 3,000,000, must possess a duly organised “tax documentation process”, with components capable of proving market parity in operations with related parties and the methods used to ascertain transfer prices.


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