Portugal: PTA has decided that Advance Pricing Agreements are the suitable mechanism to determine the transfer pricing method and the arm's lengh pricing, under intragroup service agreements
The Portuguese Tax Authorities (PTA) decided, in the context of a Binding Information Request (PIV) –Case no. 22442–, that this is not the appropriated approach for determining the transfer pricing method nor the arm’s length pricing between related parties under an intragroup service agreement. Instead, PTA considered that entering into an Advance Pricing Agreement (APA) is the suitable mechanism for these cases.China’s first attempt for Advance Tax Ruling: trail implementation in Shanghai
Shanghai introduces a trial Advance Tax Ruling (ATR) system, a significant step in China's tax administration. ATR, common in countries like Spain and the U.S., allows enterprises to seek formal tax opinions on future complex tax matters, enhancing certainty. The ATR applies to corporate taxpayers in Shanghai, though its applicability to non-resident taxpayers is subject to further confirmation with the in-charge tax authority.Spain - Tax incentives for patronage: higher personal income tax credits and corporate income tax credits
Plus, for gifts, the giver can receive goods or services from the recipient which are token in nature, and for collaboration agreements, the economic support can be in cash or in kind or consist of supplies of services where they are part of the collaborator’s specific activity.