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News & Analysis

Portugal - Beneficial owner: what’s in a name?

01 August 2023 by PLMJ - Portugal : João Guia Lopes and Afonso Massapina, associates in the Tax practice

The Portuguese Arbitration Court has recently issued the first decision on the application of the concept of beneficial owner in the context of the Interest & Royalties Directive (“IRD”).
News & Analysis

Old vs new: does the wording of the GAAR really matter?

28 June 2023 by PLMJ - Portugal : Dinis Tracana and Rita Medalho

The Portuguese Arbitration Court (‘CAAD’) has recently ruled in three similar cases dealing with the application of the General Anti-Avoidance Rule (‘GAAR’).

News & Analysis

Cooperation in tax collection: the increasing use of precautionary measures as a way of achieving a surprise effect.

18 May 2023 by PLMJ - Portugal: Priscila Santos, Raquel Santos Ferreira

In an increasingly interconnected world, where businesses expand their operations worldwide and capital flows across borders, not only does the issue of international taxation arise, but also cooperation between tax administrations, and this cooperation is an objective to be achieved in a European and international context.

News & Analysis

BEPS 2.0 Pillar Two: The minimum level of taxation for largest MNE Groups – Main challenges in the treatment of domestic tax incentives

18 April 2023 by Isaque Ramos, Ana Raquel Magalhães - PLMJ - Portugal

The adoption of the EU Minimum Tax Directive (2022/2523) ensuring a global minimum level of taxation for MNE Groups and large-scale domestic groups in the EU (also known as BEPS 2.0 Pillar Two) has raised some practical questions regarding how EU Member States will apply the global minimum corporate tax in their domestic legislation from the beginning of 2024 under the GloBE Rules.
News & Analysis

Marketing fees charged to Collective Investment Undertakings in Portugal

15 February 2023 by PLMJ - Portugal

The recent decision of the Court of Justice of the European Union (‘CJEU’) in case C-656/211, challenges the Stamp Tax liability applicable to marketing fees (and management fees including marketing services) paid by collective investment undertakings to management companies or financial entities (e.g., banks, credit institutions, etc.).
News & Analysis

Portuguese Budget Law for 2023: Real Estate Transfer Tax Developments

27 January 2023 by PLMJ - Portugal

The Portuguese State Budget Law for 2023 – in force since 1 January 2023 – brought a set of legal updates with significant impact on the real estate sector. With this in mind, we now highlight the new conditions for the application of the Real Estate Transfer Tax (“RETT”) exemption to the purchase of properties for resale and the new rules on the assessment of the taxable value of properties in real estate exchanges.