Preços de transferência
: métodos de determinação de operações que envolvem intangíveis

  • Nuno Miguel Oliveira Pereira Correia de Castro (Student)

Student thesis: Master's Thesis

Abstract

The subject we set ourselves to analyze is developed around the transfer pricing methods related to operations involving intangibles. We are facing a matter of great relevance, which results from a natural evolution of society, where the phenomenon of globalization reigns. Therefore, the ease with which a great diversity of goods and services can be put into circulation, allied to technological evolution, massively increases the flourishing of intangible assets. These, in turn, add value to companies, helping to differentiate them in the markets and, above all, generate greater wealth. This new and current economic reality brings with it new problems and new challenges for states in tax matters, which urgently need to be addressed. We refer, in particular, to the problem of determining the value of prices charged in transactions involving group companies. Indeed, in the face of such a challenge, we have focused on the analysis of the available methods for transfer pricing purposes, in order to find the most appropriate one to respond to the problem at hand. On the other hand, we address the possibility of opting for an alternative solution to transfer pricing, using the allocation method based on a global scope formula. The reflection to allowed us to know and evaluate the strengths and weaknesses of each proposed solution, so that, owing to the circumstances of the current reality, we believe we can indicate the one that seems more appropriate, namely, the method of profit split. In conclusion, we must emphasize that this study has been an excellent opportunity to deepen our knowledge about this theme which, due to its relevance, has been briefly addressed in some courses, even though it was not part of the respective syllabus. It contributed, above all, to make us aware that this is an extremely delicate and complex subject that will continue to be the object of further research and development.
Date of Award21 Jul 2021
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorJoão Sérgio Ribeiro (Supervisor)

Keywords

  • Intangible assets
  • Transfering prices
  • Arm´s lenght principle
  • Transfer pricing methods
  • Comparable uncontrolled price method
  • Profit split method
  • OCDE
  • Formulary apportionment

Designation

  • Mestrado em Direito

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