Transfer Pricing

The increasing internationalisation of companies, the high complexity of economic groups and intragroup transactions make transfer pricing policies a central tax concern of companies and tax administrations across the world.

A proactive approach to risk analysis and timely management of procedures and policies is essential to anticipate and mitigate future contingencies, by implementing tax-effective legal solutions with the support of a team with a broad and expert vision of the company’s activity in the preparation of a strategic and competitive transfer pricing plan.

Abreu Advogados takes on an active role in transfer pricing matters since it was incorporated in 1993, assisting its clients in matters as diverse as:

• Supporting negotiations and concluding Advance Pricing Agreements;
• Supporting the legal structuring of intragroup transactions in a strategic, responsible, and consistent manner;
• Analysing the legal risk arising from transfer pricing practices and proposing measures to mitigate litigation risks;
• Representing companies in litigation proceedings against the tax Authority, either before national courts, the CAAD (Administrative Arbitration Board), or through mutual agreement as provided for in conventions aimed at avoiding double taxation, or in arbitration under Convention 90/436/EU or Directive (EU) 2017/1852;
• Monitoring OECD transfer pricing changes (including as a result of the BEPS initiative) and suggesting measures for companies to adapt to such changes;
• Verifying compliance with the requirements laid down in the (current) Ministerial Implementing Order No 268/2021 of 26 November 2021;
• Preparing or revising transfer pricing dossiers;
• Analysing transfer pricing methods.