A crise dos comparáveis
: preços de transferência em situação de crise económica

  • Guilherme João de Mendonça Medeiros (Student)

Student thesis: Master's Thesis


In an ever increasingly global world, companies take advantage of every opportunity andeasiness to establish themselves on different countries in order to optimise their operation,hence increasing their profits.That would be yesterday’s news weren’t taxes one of the main sources of State income, that,under the banner of a “fair taxation”, only seek to enforce their taxes so they can avertevasion to other lower taxes jurisdictions. This is where transfer pricing comes in play.So far OECD seems to be in agreement: find a market comparable using the same factors(prices, gross margins and profits)The challenge comes forth, same across other areas of legislation, when the reality surpassesthe conditions of the law. Namely, when the law in force isn’t applicable to the reality. With the dematerialization of trade, the ever growing digitalisation of economy, economic crisis and pandemics, this has never been so true in transfer pricing. In this paper, we set ourselves to analise the traditional transfer pricing model and test it’s (un)suitability to modern times as well as determine if there are is a better model that can riseto the challenge of transfer pricing in economic downturn.
Date of Award18 Oct 2022
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorSérgio Vasques (Supervisor)


  • Transfer-pricing
  • Arm’s length principle
  • Global formulary apportionment


  • Mestrado em Direito

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