Portugal has published Ordinance No. 268/2021 of 26 November 2021, which revises the regulation of transfer pricing in transactions carried out between taxable persons and any other entity under Article 63 of the Corporate Income Tax (IRC) Code, replacing Ordinance No. 1446-C/2001 of 21 December 2001. Ordinance No. 268/2021 takes into account international developments in the area of transfer pricing in recent years, including the 2017 OECD Transfer Pricing Guidelines and other OECD guidance issued as a result of the BEPS project, including guidance on the application of the profit-split method, the approach to hard-to-value intangibles, financial transactions, and permanent...