A Portuguese arbitration court (Tribunal Arbitral) denied the tax authority’s transfer pricing challenge of a multinational’s cash pooling arrangement because its use of the comparable uncontrolled price (CUP) method was inappropriate. The case should alert Portuguese taxpayers to review the arm’s-length nature of their cash pooling arrangements.
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Building a transparent culture, prioritising internal promotions and being different from the big four are all key features of A&M Tax’s ambitious plans for India
But businesses should remain flexible when choosing between internal and external resources to handle added ViDA complexity, ITR’s Indirect Tax forum also heard