Corporate Services by ECCO

1. M A D E I R A
PART II :
ACTIVITIES / INVESTMENT
WE CREATE GLOBAL SOLUTIONS
ECCO EFFICIENT CONSULTING
IBC

2. P A R T I I :
A C T I V I T I E S / I N V E S T M E N T
CONTENT
GENERAL ASPECTS . . . . . . . . . . . . . . . . . . .
ACTIVITIES / INVESTMENT . . . . . . . . . . . .
INTERNATIONAL SERVICES. . . . . . . . . . . . .
INDUSTRIAL FREE ZONE . . . . . . . . . . . . . . .
INTERNATIONAL SHIPPING REGISTER-
MAR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
CHARACTERIZATION OF THE COMPANIES
CURRENTLY OPERATING IN THE IBC OF
MADEIRA. . . . . . . . . . . . . . . . . . . . . . . . . .
STRUCTURES . . . . . . . . . . . . . . . . . . . . . . .
MAR . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
02
03
04
05
06
07
11
17

3. IBC
Regime IV agreed with the EC on March and
approved by Law 64/2015 of July 1, adding Art.
36-A to the EBF. Permits the setting up of new
companies up to the end of 2020.
Effects produced till the end of 2027, Stable
regime due to the prior agreement with, and the
fulfilment of the guidelines and rules of, the EU, as
well as alignment of the BEPS Regime accessible to
worldwide shareholders, including residents in
Portuguese territory.
PAGE 02
G E N E R A L A S P E C T S

4. IBC
International Services
PAGE 03
A R E A S O F A C T I V I T Y A N D I N V E S T M E N T
Industrial Free Zone
MAR – International Shipping
Register
Régimen CINM

5. IBC
“Trading” (import/export);
Holding Companies (Management of
shareholdings);
Intellectual property;
Assets management;
E-commerce and telecommunications;
Maritime transportation companies;
Rendering of services in general.
PAGE 04
INTERNATIONAL SERVICES- ACTIVITIES

6. IBC
Industrial Park with 140 hectares;
Activities of transformation, assembly and
warehousing;
Installation in platforms duly prepared for the
construction of buildings or in modulated
warehouses;
Application of the IBC regime to profits coming
from the national market in transforming
activities;
Possibility of deduction of 50% of the taxable
income for activities with great economic impact
or technological innovation;
Application of the suspensive customs regime.
PAGE 05
INDUSTRIAL FREE TRADE ZONE
ACTIVITIES

7. IBC
Allows the registration of commercial vessels,
yachts and oil rig platforms;
Fourth bigger Register of the E.U. in number of
vessels and third in tonnage: 399 vessels /
7,9M GT;
Flexible crew citizenship requirements;
Very competitive social security regime;
Non classified as “flag of convenience” by the
I.T.F.;
The Register does not require the incorporation
of a company
PAGE 06
INTERNATIONAL SHIPPING REGISTER OF
MADEIRA - MAR

8. IBC
PAGE 07
CHARACTERIZATION OF THE COMPANIES
CURRENTLY OPERATING IN THE IBC OF
MADEIRA
ORIGIN OF THE COMPANIES:

9. IBC
PAGE 08
CHARACTERIZATION OF THE COMPANIES
CURRENTLY OPERATING IN THE IBC OF
MADEIRA
SEGMENTS WHERE PORTUGUESE
COMPANIES ARE INTEGRATED:
Trading/ Rendering of services – 62%
Holding companies – 13%
International maritime transportation – 10%
Industrial – 3%
International property and image rights– 3%
Telecommunications – 2%
12 Portuguese vessels registered in MAR (4% of total).

10. IBC
PAGE 09
CHARACTERIZATION OF THE COMPANIES
CURRENTLY OPERATING IN THE IBC OF
MADEIRA
SOME OF THE MAIN NATIONAL COMPANIES
OPERATING IN THE IBC

11. IBC
PAGE 10
CHARACTERIZATION OF THE COMPANIES
CURRENTLY OPERATING IN THE IBC OF
MADEIRA
SOME OF THE MAIN INTERNATIONAL
COMPANIES OPERATING IN THE IBC

12. IBC
PAGE 11
STRUCTURES
TRADING
Distributing company
In the IBC
Companies/
Individuals shareholders
Non resident in
Portugal
Clients in the
PALOPs
Clients
abroad
Other companies
abroad
Distributor buys/ imports goods and resell/ export it
0%
Taxation
of the
dividends
Tributação
dos
dividendos
5%
Profits
of the
sales

13. IBC
PAGE 12
STRUCTURES
HOLDING
Madeira
Holdco
Foreign Investor/
Investing Co
Foreign
Opco
0%WHT
Tributação
dos
dividendos
0% (*) or 5%
WHT
(*) Under the Participation Exemption Regime, when certain requirements are met,
exemption applies
0% (*)
Sale of the
Madeira HoldCo
0% (*)
Sale of
subsidiaries
Div.
distributed
Profits
of the sales
Madeira/Portuguese companies benefit from the Portuguese CIT International
Participation Exemption
Under the IBC tax regime exemption applies on dividend distribution from Madeira
HoldCo to non-residents (individuals or companies) in Portugal or in tax heavens
The Treaties network may reduce/eliminate taxation on dividends or capital gains
Tax Credit by international double taxation (DTT) applicable

14. IBC
PAGE 13
STRUCTURES
VEHICLE OF EXPORTS FOR PORTUGUESE
ECONOMY
Distributing Company
In the IBC
Portuguese
Exportin Company
Clients in the
PALOPs
Clients abroad Other companies
abroad
**
0%
Dividends
Received
WT on
dividends
**
1- Distributor buys goods under agreement celebrated between both parties
2- Distributor undertakes, on its own name and account, the activity of purchase
for resale
0%
WT on
dividends

15. IBC
PAGE 14
STRUCTURES
VEHICLE OF RENDERING OF INTERNATIONAL
SERVICES
IBC Company
Companies/
Individuals shareholders
Non resident in
Portugal
Client 1 Client 2 Client 3
0%
Taxation of
dividends
5%
Profits
(with tax credit)
Payment ofServicesWT at internal orreduced rate/inexistent bymeans of the DTT

16. IBC
PAGE 15
STRUCTURES
IMAGE RIGHTS / INTELLECTUAL PROPERTY/
PATENTS
IBC Company
Companies/
Individuals Shareholders
non resident in Portugal
UE Off the UE Third countries
0%
Taxation of
dividends
5% o 2,5%
Taxation of
royalties
Payment ofRoyaltiesWT at the local rate
EU: 0% Interest/
Royalties Directive
It transfers the use
of the trademark
patent

17. IBC
PAGE 16
STRUCTURES
STRUCTURE IN THE INDUSTRIAL FREE ZONE
( IFTZ)
Company
with industrial activity
in the IFTZ
Companies /
Individuals Shareholders
resident or not in Portugal
UE Out of the EU Portugal
0%
Taxation of
Dividends
5% ou 2,5%
Taxation of
Dividends
**
Interest orother formsof income ofsupplements0% WT
**
5% or 2.5% (as long as they contribute
cumulatively for 2 amongst the following
situations: (1) modernization, (2) diversification of
the economy, (3) employment of very skilled staff,
(4) improvement of the environment, (5) creation
of > 15 jobs for a minimum of 5 years)

18. IBC
PAGE 17
MAR – MADEIRA’ S INTERNATIONAL
SHIPPING REGISTER
VESSELS ACCEPTABLE FOR REGISTRATION
Commercial Vessels (*)
Pleasure Crafts
* Access restrictions: Professional fishing vessels – non authorized
APPLICANTS FOR THE REGISTRATION OF
COMMERCIAL VESSELS
Companies, Branches, Rep offices, other legal structures
and their forms of representation
Activities: Commercial maritime transportation of cargo or
of passengers with own or chartered vessels
With or without registered office in Madeira, licensed and
incorporated, or not, to operate in the ambit of Madeira’s
IBC (**)
** Local legal representation (ex.: P.O.A.) before the authorities and third parties, including to
receive citations

19. IBC
PAGE 18
MAR – MADEIRA’ S INTERNATIONAL
SHIPPING REGISTER
COMMERCIAL VESSELS – CREW
REQUIREMENTS
30% of the minimum safety crew must be citizens of the
EU, EEA or one of the Portuguese officially speaking
countries– Angola, Brazil, Cape Verde, East Timor,
Guinea Bissau, Mozambique & São Tomé & Príncipe
Foreign crewmembers and respective employers are not
complied to contribute to the Portuguese social security
scheme, notwithstanding however, of having to comply
with minimum requirements established by the IMO (public
or private alternative protection system); The Portuguese
ones are nevertheless subject to a reduced contribution
rate of 2.7% (2.0% a supported by the employing entity
and 0.7% by the crewmember).
Crewmembers are exempt from individual income tax in
Portugal on income earned aboard the said vessels in such
quality and whilst the respective registration remains
valid.
NATIONALITY
TAX BENEFITS

20. IBC
PAGE 19
MAR – MADEIRA’ S INTERNATIONAL
SHIPPING REGISTER
COMMERCIAL VESSELS – CREW
REQUIREMENTS
Need to submit a proposal accompanied by the following
information:
MINIMUM SAFETY CREW
CERTIFICATES OF COMPETENCY STCW 78/95
Recognition required by the DGRM (Maritime Administration)
in relation to foreign officers
Intended navigation area of the vessel (coastal, offshore,
sea going);
Gross & Net tonnage of the vessel, length, breadth and
draught;
Radio communications equipment and navigation ancillaries;
Power HP of the machineries and whether UMS or not

21. IBC
PAGE 20
MAR – MADEIRA’ S INTERNATIONAL
SHIPPING REGISTER
ENTITIES LICENSED FOR MARITIME
TRANSPORTATION
Income resulting from the licensed activity that do not
derive from passengers or cargo transportation between
Portuguese ports (national cabotage): CIT at the rate of
5%
Partners or shareholders of licensed companies, resident
or not in Portugal are exempt from individual or corporate
income taxation in Portugal on profits put at their disposal
(Art. 36-A nº 10 a) & nº 11 b) of EBF) & on income resulting
from interest and other forms of remuneration of
supplements, bails or advanced payments of capital (Art.
36-A nº 10 b) & nº 11 b) do EBF)
TAX BENEFITS

22. M A D E I R A
WE CREATE GLOBAL SOLUTIONS
ECCO EFFICIENT CONSULTING
Rua da Queimada de Cima nº28, 3º P
9000 - 065
Funchal - Madeira | Portugal
(+351) 291 771 323
info@efficientconsulting-co.com
www.efficientconsulting-co.com
@eccoconsulting