Changes to the transfer pricing framework

Changes to the transfer pricing framework

Law no. 119/2019


Law no. 119/2019 was published yesterday, introducing modifications to the transfer pricing regime which will enter into force on October 1st, 2019, with effects on January 1st, 2020.

Among those, we highlight the mandatory submission of the transfer pricing documentation by the Major Taxpayers (no later than the 15th day of the 7th month following the tax year-end).

In addition, the Portuguese regime has been aligned with the OECD transfer pricing Guidelines, the timeframe applicable to the Advance Pricing Agreements (“APA”) is extended from 3 to 4 years, and the transfer pricing adjustments conducted by the Portuguese Tax Authorities – triggered by the non-compliance of the arm’s length principle – shall now be subject to the tax period where the controlled transaction(s) impacts were deemed relevant to assess the tax profit or loss.

As per the above, we recommend an analysis of the transfer pricing policies adopted in the context of related parties.

For additional information, please refer to the document attached herein.


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