Baker Tilly operates a specialist transfer pricing team in Portugal, led by transfer pricing partner Joao Aranha. He is supported by a number of senior consultants including Inês Fain. The firm has capabilities in financial and economic analysis, as well as having legal experts in-house capable of advising on the legal aspects of transfer pricing policy.
The firm is currently assisting an international printing company, with subsidiaries across the world, on designing an alternative transfer pricing model for structuring inter-company transactions. It conducted analysis on the current financing and value chain models, in order to identify the best modifications to the group’s policy.
Deloitte has a very large transfer pricing practice in Portugal, with offices in Lisbon and Porto. The team consists of 28 specialists with partner Patrícia Matos, who has worked for the firm for 22 years, leading the team. It is capable of advising on the fiscal, economic and legal aspects of transfer pricing policy through both its in-house team and its connection to the wider Deloitte TP network.
The firm has been advising two companies. One financial services and one pharmaceutical, regarding the BEPS project and the implications on the fragmentation of the value chain by multinational groups. Both clients were at risk from tax audits in connection to a potential taxable presence for corporate income tax purposes of non-resident entities. The team assisted with the analysis and adjustment of the value chain, in order to mitigate the risk to the clients.
The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness Platform, Solutions & Intelligence and operational transfer pricing practice serving clients’ needs across all jurisdictions.
Led by well-recognised, Oslo-based partner Sveinung Baumann-Larsen, the operational transfer pricing team brings together multi-disciplinary experience and resources focusing on IT, accounting, and tax from the entire region to bring to bear in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals.
Garrigues' transfer pricing practice has grown significantly in recent years. It now advises numerous clients on the transfer pricing aspects of business reorganisations, including counsel before and after the reorganisation. The firm also works to analyse and determine the arm’s-length principle for controlled transactions, as well as utilising its strong controversy team to assist clients in transfer pricing litigation.
The firm recently advised the Portuguese subsidiary of a multinational financial institution on determining the necessary free capital per branch, as well as considering the effect of inter-branch flows, on the profit allocation methodology for a Portuguese permanent establishment.
KPMG's Portuguese transfer pricing division is led by associate partner Susana Pinto, who represents the team in KPMG's global transfer pricing services line. Her practice is focused on providing support to clients in litigation and with APA negotiations, as well as assistance on TP policy preparation and application.
Pinto has advised clients from industries, including insurance and telecoms, on the application for, and negotiation of, an APA. Pinto has also advised an MNE from the automotive sector on value chain analysis and a reassessment of the pricing policy of a number of sectors of the business. Pinto is also counselling on a litigation case for a client operating in the energy sector.
Through its international connections and strong presence in Portugal, PwC offers a complete TP service for its clients. It transfer pricing team includes 26 professionals. This includes lead partner Jaime Carvalho Esteves and transfer pricing specialist partner Leendert Verschoor, who is a dual qualified lawyer and economist. The firm is also heavily involved in the introduction of transfer pricing regulation to Angola.
The team recently provided assistance to a major private equity firm active in Portugal, with the evaluation of the transfer pricing policy used for financial transactions. The private equity firm is involved in a number of transactions providing shareholder loans, which have the potential to be converted into equity. It was tasked with conducting analysis to ensure that the transfer pricing policy of the private equity group remained in line with the arm's-length principle.
Uría Menéndez – Proença de Carvalho uses its expertise within transfer pricing to assist its clients with pre-transaction and post-transaction structuring. The firm undertakes all benchmarking and policy analysis and advises on all legal aspects of the implementation of new or amended transfer pricing policies.
The firm is also currently advising a number of private individuals, as well as the family offices of HNWIs who have transferred their tax residency to Portugal, on the application of transfer pricing policies, including the restructuring of the family offices in order to take full advantage of beneficial Portuguese initiatives.