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New anti-avoidance rules were published on 14 February 1995 which relate to transactions with or investments in non resident entities with a favourable tax regime. For these purposes a favourable tax regime is normally one where amounts of income are taxed a rate of less than 20% or the nominal income tax rate is 20% or less.
Payments made by Portuguese residents to such countries are now presumed not to be tax deductible for the payer unless they can be demonstrated to relate to actual services made or goods provided, were not of an abnormal character and the price paid was not excessive.
Where a Portuguese resident shareholder holds directly or indirectly more than 25% of a company in such a territory (or holds more than 10% where the total shareholding by Portuguese residents is more than 50%) then undistributed profits are treated as income of the shareholder and taxed on him in Portugal. In order to be exempt from such deemed income a number of specific requirements must be met. Generally banking and finance activities will not be able to meet the exemptions.
There are a number of features of the new law which remain unclear and are the subject of discussions with the tax authorities.
For further information please contact Mark Gibbins, tax partner, KPMG Peat Marwick, telephone: +351 1 311 04 06.
International Financial Reporting Standards (IFRS) are constantly evolving, providing new ways for businesses to present their financial position and performance...
On April 6, 2024, the Decree Amending the Decree numbered 8313 on the Determination of Companies Subject to Independent Audit ("Decree") ("Amending Decree") was published in the Official Gazette dated April 6, 2024 and numbered 32512.
6 Nisan 2024 tarihli ve 32512 sayılı Resmî Gazetede yayımlanan 8313 sayılı Bağımsız Denetime Tabi Şirketlerin Belirlenmesine Dair Kararda Değişiklik Yapılmasına İlişkin Karar ("Değişiklik Kararı") ...
6 Nisan 2024 tarihinde 32512 sayılı Resmi Gazete'de 8313 sayılı Bağımsız Denetime Tabi Şirketlerin Belirlenmesine Dair Kararda ("Karar") Değişiklik Yapılmasına İlişkin Karar ("Değiştiren Karar") yayımlandı.
Bağımsız Denetime Tabi Şirketlerin Belirlenmesine Dair Kararda Değişiklik Yapılmasına İlişkin Karar ("Değişiklik Kararı"), 6 Nisan 2024 tarihli Resmi Gazete'de yayımlandı.
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