Portugal's 2014 Budget included several changed to transfer pricing rules. The following provides a summary.
Expanded Access to Unilateral APAs
Under the previous rules, advanced pricing agreements (APA) were only available in cases where there was no tax treaty between Portugal and the home jurisdiction of the counterparty. under the new revised rules, unilateral APAs are possible regardless of whether or not a tax treaty is in place.
Ownership Requirement Increased
The ownership percenta…