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Portugal: Transfer pricing documentation, other measures effective 2020

Portugal: Transfer pricing documentation

Changes to the transfer pricing rules in Portugal will be effective 1 January 2020.

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Lei n.º 119/2019 introduces amendments to the transfer pricing rules beginning in 2020 including the following:

  • A requirement to submit transfer pricing documentation by those taxpayers that are subject to the jurisdiction of the large taxpayer unit (Unidade dos Grandes Contribuintes)—under these measures, the transfer pricing documentation is due by a date that is the 15th day of the seventh month following the end of the tax period.
  • Extension of advance pricing agreements (APAs) from the current three-year period to four years (this aligns with the rules under the OECD Transfer Pricing Guidelines).


Read a 2019 report (Portuguese) and (English) prepared by the KPMG member firm in Portugal

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