Executive summary
With the publication of Decree-Rulings 267/2021 and 268/2021, both dated 26 November 2021, significant changes have been made to Portugal’s advance pricing agreement (APA) regime, provided for in Article 138 of the Corporate Income Tax (CIT) Code, and to the regulation of transfer pricing (TP) in transactions carried out between Personal Income Tax (PIT) or CIT taxpayers and any other entity, under Article 63 of the same code.
These changes were made in light of the experience ga…