To print this article, all you need is to be registered or login on Mondaq.com.
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.
In order to ensure a high level of data protection within the
EU, the GDPR provides for strict compliance responsibility on the
part of companies processing personal data.
This newsflash highlights the features of the new Circular CSSF 23/845 that is relevant for credit institutions incorporated under Luxembourg law,1 including their branches...
A number of clients and contacts ask for general details regarding Swiss accounting and audit requirements, and we have therefore provided the following summary.
06 Nisan 2024 tarihli ve 8313 sayılı Cumhurbaşkanlığı Kararıyla "Bağımsız Denetime Tabi Şirketlerin Belirlenmesine Dair Kararda Değişiklik Yapılmasına İlişkin Karar " yayımlanmıştır.
There are huge technological advancements in financial software packages these days and new names popping up all the time. If you're thinking about changing your financial accounting software...
In February and March 2024, the Luxembourg Accounting Standards Board (CNC) published two Q&As_ (No. 24/031 and No. 24/032) that provide useful guidance...
FREE News Alerts
Sign Up for our free News Alerts - All the latest articles on your chosen topics condensed into a free bi-weekly email.