Garrigues Portugal
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Sponsored by Garrigues PortugalA recent Portuguese Arbitration Court decision (Case 639/2017-T), dealing with the application of the exemption method to foreign-based liquidation proceeds for non-habitual tax residents serves as a good illustration of how this domestic exemption works.
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Sponsored by Garrigues PortugalThe option for VAT taxation of the supply of Portuguese real estate has recently been characterised by uncertainty, and the latest European ruling hopes to clarify matters.
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Sponsored by Garrigues PortugalThe taxation of income had been unclear since the recent boom in cryptocurrency trading. The new ruling has come to the delight of tax authorities.
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Sponsored by Garrigues PortugalThe Portuguese tax authorities recently published three rulings covering taxation of income derived from foreign fiduciary structures by resident individuals.
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Sponsored by Garrigues PortugalA country's tax policy is reflected in its domestic tax legislation as well as its tax treaty positions.
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Sponsored by Garrigues PortugalPortugal has historically favoured source-based taxation on passive income, which has been coupled with stringent documentation requirements to claim the application of tax treaties (the so-called RFI forms). The Portuguese tax authorities have recently published a new set of procedural forms, this time to apply the transitional regime under the interest and royalties directive (council directive 2003/49/EC). Those developments provide a good pretext to outline the current state of play concerning outbound interest and royalty payments.