Portugal vs “Welding Mesh SA”, December 2021, CAAD Tax Arbitration, Case No 194/2021-T

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A Portuguese subsidiary – A SA – had received intra group loans in foreign currency and had various other transactions with foreign group companies.

The tax authorities claimed that the pricing of the transactions had not been at arm’s length and that the interest payment and exchange losses on the loans were not tax deductible.

Decision of CAAD

The CAAD set aside the assessment and decided in favour of “Welding Mesh SA”

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Portugal - P194_2021-T - 2021-12-07

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