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Portugal introduced changes to its Advance Pricing Agreement (APA) regime and transfer pricing (TP) documentation requirements on November 26, 2021. Following these amendments, TP documentation must be prepared by July 15 of the year following the tax calendar year (or the 15th day of the 7th month of the year following the taxpayer’s fiscal year-end). Most large taxpayers also are obliged to deliver the TP documentation file to the Portuguese Tax Authorities.

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