The law transposing Council Directive (EU) 2018/822 of May 25, 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements (known as DAC 6) was published in the Official State Gazette on December 30, 2020. For now, however, the dates when it will be necessary to begin to make the relevant reporting are not known.
On December 18, 2020, the Organization for Economic Cooperation and Development (OECD) published guidance (access here) to clarify and illustrate the practical application of the arm’s length principle in controlled transactions affected by the COVID-19 crisis. In light of the contents of the guidance, taxpayers should analyze the effects of the pandemic on their transfer pricing policies, adjust their economic analyses, review their intragroup agreements and verify whether there will be any substantial change in their advance pricing arrangements.
The form (Model 58) to comply with the report obligation to the Portuguese Tax Authority (AT) of the so-called "arrangements" was finally approved by Ministerial Order no. 304/2020, of 29 December.
Following the United Kingdom withdrawal from the European Union and the end of the transition period on 31 December 2020, it was approved, by Dispatch no. 514/2020.XXI, a transitional regime applicable to UK residents for the mandatory appointment of a tax representative.
The Portuguese Government approved, through Decree-Law 103-A/2020, of 15 December, a new regime for the payment of VAT, in three or six instalments, to be implemented during the first half of 2021.
The president has just signed a new Financial Shield to help entrepreneurs most affected by the second wave of the SARS-CoV-2 pandemic. The call for electronic applications is planned for the second half of January 2021. The amount of aid planned is estimated at PLN 40 billion.