000			01823nab a2200241 c 4500
999			_c143485 _d143485
003			ES-MaIEF
005			20210202115516.0
007			ta
008			210202t2020 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100	1		_953126 _aMartins, Antonio
245		0	_aGroup transactions, transfer pricing and litigation _bevidence from Portugal _c António Martins, Sandrina Correia & Daniel Taborda
260			_c2020
500			_aResumen.
520			_aIn Portugal, in the wake of the introduction of tax arbitration in 2011, courts have ruled in several cases involving transfer pricing (TP) judicial conflicts. The research questions that this article addresses are: What are the core issues in TP litigation in Portugal? Do they follow international trends? What is the predominant outcome of arbitration rulings, and why do tax authorities experience defeat in so many TP cases? Based on the total (thirty-two) TP arbitration cases decided in Portugal from 2012 to 2017, the authors find that tax administrations were successful in only three cases. Courts also found that tax audit reports often misused the comparability concept, and the methods that were used were also often disallowed by arbitrators. Therefore, tax administrations should proceed with caution in audits and seek robust foundations to TP adjustments. Multinational groups must also carefully substantiate their related party transactions in order to minimize audit risk and compliance costs of taxation.
650		4	_aPRECIOS DE TRANSFERENCIA _948095
650		4	_aARBITRAJE _928417
650		4	_aPORTUGAL _948081
700	1		_968695 _aCorreia, Sandrina
700	1		_968696 _aTaborda, Daniel
773	0		_9164078 _oOP 2141/2020/11 _tIntertax _w(IEF)55619 _x 0165-2826 _gv. 48, issue 11, November 2020, p. 998-1011
942			_cART