Portuguese government recently approved the Corporate Income Tax (CIT) reform. The key elements of the reform offer simplification, increased competitiveness and decreased CIT. These new rules have come into force from 1 January 2014, reports Nair & Co.’s International Tax team.

1. Portugal Amends Income Tax Law
(Bristol, UK) - The Portuguese government recently approved the Corporate Income Tax (CIT) reform.
The key elements of the reform offer simplification, increasedcompetitiveness and decreased CIT. These
new rules have come into force from 1 January 2014, reports Nair & Co.’s International Tax team.
Updates to the Corporate Income Tax law are as follows:
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Corporate Tax Rate:
 Lowering of the CIT rate to 23% (previously 25%)with further reduction to 21% in 2015
subject to some conditions.
 17% tax rate applied to the first €15,000 of taxable income earned by SMEs.
State Surcharge :
 7% State Surcharge payable on taxable profits more than €35million (previously 5%).
Dividend and Capital Gains Participation Exemption Rules:
 Shareholding participation reduced to 5% minimum holding (previously 10%).
 Shareholding period increased to 24 months (previously12 months).
 companies distributing dividends may be subject to CITor comparable tax.
Extended the Period for Carry Forward of Losses:
 12 tax years are allowed to carry forward losses for the purpose of taxation (previously 5
tax years). This shall be applicable only to losses incurred in year 2014 and onwards.
 Allowable losses are limited to 70% (previously 75%).
Transfer Pricing Rules:
 20% participation threshold is applicable (previously 10%).
 Rules are extended to cover transactions between foreign Permanent Establishments
(PE) and local head office/other permanent establishments.
Maintaining Accounting Records:
 It is now mandatory to maintain accounting records for a period of 12 years (previously
10 years).
Entities having operations in Portugal or those planning to set base in the country may find the above
proposals beneficial due to reduction in the effective CIT rate.
For more information about doing business overseas or to know more about ourInternational Expansion
Services team please contact us.
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