Volume 39 (2011) / Issue 4
The purpose of this work is to provide an in-depth analysis of the topic of transfer pricing documentation within the context of inter-company transactions entered into with non-resident enterprises, in view of amendments recently introduced by Decree-Law No. 78 of 31 May 2010. To such end, it would be useful to focus on the development of the debate that has been taking place in the last few years within an international scenario relating to the need to provide documentary requirements to justify - in case of tax audits by the tax authorities - the application of certain inter-company prices.
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