On 9 September 2026, the Portuguese Tax Association (Associação Fiscal Portuguesa – AFP) officially launched its new International Taxation Program, a specialized training initiative designed to address the growing complexity of cross-border tax compliance for multinational enterprises and tax practitioners operating in Portugal. The program arrives amid significant regulatory shifts, including the ongoing implementation of OECD Pillar Two global minimum tax rules, recent updates to the EU DAC7 directive on digital platform reporting, and Portugal’s revised transfer pricing documentation requirements under Decree-Law 144/2017. The curriculum is structured to provide both theoretical foundations and practical case studies, covering permanent establishment risks, controlled foreign company (CFC) rules, hybrid mismatch arrangements, and the mutual agreement procedure (MAP) under double tax treaties. The AFP emphasized that the program responds to member demand for structured, high-level education on international tax developments following the rapid legislative changes introduced by the 2024 and 2025 State Budget laws, which expanded anti-abuse provisions and introduced new reporting obligations for taxpayers with cross-border activities. Additionally, the course incorporates analysis of recent European Court of Justice rulings on fundamental freedoms and state aid, as well as Portuguese Supreme Administrative Court decisions shaping the interpretation of treaty benefits and anti-avoidance rules.
Key Takeaways
- Comprehensive Curriculum Aligned with OECD BEPS 2.0: The program integrates the latest OECD Inclusive Framework outcomes, including detailed modules on Pillar Two GloBE rules implementation in Portugal, qualified domestic minimum top-up tax (QDMTT) mechanics, and transitional safe harbours for multinational groups with revenue exceeding €750 million. Participants will gain hands-on experience calculating top-up tax liabilities, applying the substance-based income exclusion, and navigating the complex interplay between domestic law and EU directives.
- Practical Focus on Portuguese Compliance Obligations: Sessions address Portugal-specific filing requirements such as the annual transfer pricing disclosure (IES/DA), country-by-country reporting (CbCR) notifications, and the new mandatory disclosure regime for cross-border arrangements (DAC6) as transposed into Portuguese law. The program also covers recent Portuguese Tax Authority (AT) guidance on intra-group financing, intellectual property licensing, and management fee deductibility, providing templates and checklists for immediate application.
- Expert-Led Delivery with Certification: The course is delivered by leading tax partners from Big Four firms, former tax administration officials, and academic specialists, offering participants a recognized AFP certification that satisfies continuous professional development (CPD) requirements for chartered tax advisors in Portugal. The blended learning format combines live virtual sessions with on-demand modules, allowing flexibility for busy professionals while ensuring interactive discussion of complex case studies.
- Networking and Regulatory Engagement Opportunities: Beyond technical content, the program includes exclusive roundtables with Portuguese Tax Authority representatives and OECD delegates, enabling participants to discuss practical implementation challenges and provide feedback on upcoming public consultations. This direct engagement channel is particularly valuable as Portugal prepares its administrative guidance for Pillar Two effective from fiscal years starting 31 December 2026.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement