Portuguese Court Holds Deduction of Arm's Length Payment to Low-Tax Jurisdiction May Not be Denied

Portugal's Central Administrative Court of the Southern Region issued a decision on 11 January 2024 regarding the deductibility of payments made to low-tax jurisdictions. The case involved a large company engaged in maintenance, repair, and modification services for aircraft in several countries. As part of its operations, the company engaged an intermediary brokerage service provider to negot…