Os preços de transferência na jurisprudência arbitral

Abstract

The present dissertation is based on the theme “Transfer Pricing in Arbitral Jurisprudence”, to obtain a Master`s degree in tax law from Universidade Católica Portuguesa – Centro Regional do Porto, Law School. We begin by briefly introducing the sequence of our work, starting with the characterization of transfer pricing, referring to the aspects of the arm’s length principle, traditional methods, the burden of proof and special relations. We also address article 77 of the Portuguese General Tax Law and Tax Litigation or Mere Annulment. Lastly, the essential nucleus of our work is followed by the intention of concentrating decisions made by CAAD in three distinct areas: cash pooling contracts, the cases of Oporto wine and the case of football. Therefore, our intension is to contribute to a better interpretation of what has been done in this respect.

Date of Award	18 Oct 2017
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Tomás Tavares (Supervisor)