Impacto do BEPS nos preços de transferência

Abstract

This paper is based on a research at the Tax Department in PricewaterhouseCoopers, with a view to complete a Masters in Finance at the Faculty of Economics and Management, Portuguese Catholic University. A globalised economy increases the importance of the issue of transfer pricing, both economic and tax respectively. In able to ensure greater transparency of the tax authorities, herein the member states of the Organisation for Economic Co-Operation and Development (OECD), the particular purpose was to combat base erosion and profit shifting through a proposed body, Action Plan BEPS, enacted by the OECD itself. Therefore, this paper is based on the analysis of the BEPS Action Plan and to further analyze its impact on transfer pricing. Firstly, we made a presentation of the host entity and a description of the activities carried out throughout our course of internship, concluding with a critical analysis of the company; both in relation to its operation and our work assignments. Secondly, the study is based on the topic of BEPS and its impact on transfer pricing. Initially, a theoretical exposure of the topic is made, focusing on the rules on transfer pricing, followed by a study of the BEPS mechanism and the OECD recommendations to combat it. Finally, we conducted a practical framework of the topic by presenting the implications that the BEPS Action Plan has on transfer pricing.

Date of Award	21 Dec 2015
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Paulo Alves (Supervisor)