Miguel Teixeira de Abreu publishes article in Cadernos de Preços de Transferência

Miguel Teixeira de Abreu, founding partner of Abreu Advogados, published an article in “Cadernos de Preços de Transferência” (Transfer Pricing Notebooks), edited by Almedina.

In this article, Miguel Teixeira de Abreu analyses the relationship between Portuguese transfer pricing rules and the general anti-abuse clause. The article focuses on Article 63 of the IRC Code and Article 9 of the OECD Model Convention, clarifying the limits to tax administration intervention in international operations and emphasising the balance between freedom of tax management and tax equality.

See the full article here (only in Portuguese)