State Budget State Budget Main Tax Changes CIT
|
|
- Sibyl McDowell
- 6 years ago
- Views:
Transcription
1 State Budget State Budget Main Tax Changes With the State Budget Proposal for 2007 currently under discussion in the parliament, we felt it might be useful to highlight the main tax changes to be introduced to Corporate Income Tax (CIT), Value Added Tax (VAT), Municipal Tax, Transfer Tax, Tax Benefits, Mortgage-Backed Bonds and Real Estate Funds. Our observations are informal and based on the proposal available. CIT EU Participation Exemption Reduction from 20% to 15% of the minimum stake to be held by an EU company in a Portuguese company for the purposes of participation exemption. Clarification of how the participation exemption applies to dividends paid to permanent establishments. Participation Exemption and Switzerland Provision of a similar EU participation exemption regime to dividends paid by Portuguese companies to companies residing in Switzerland. Inventories Revocation of the tax benefit applicable to taxpayers who use the permanent inventory system. Provisions for Banks / Insurance Companies Definition, by means of cross-reference to the rulings issued by the respective regulators (Banco de Portugal and Instituto de Seguros de Portugal), of the types of provisions relevant to financial and insurance entities for tax purposes. Definition of the limits, terms and conditions for the tax deduction for these sectors under the relevant provisions. Fringe Benefits Broadening of the concept of fringe benefits so that the amounts paid for post-employment health benefits can be considered relevant for tax purposes. This change takes effect from 1 January Internal Participation Exemption Possibility of deducting 50% of the dividends distributed by EU companies qualifying under the Parent- Subsidiary Directive whenever the acquisition value of the stake is lower than 20,000,000 or when it represents less than 10% of the company s November
2 share capital. Revocation of the anti-avoidance rule created by the 2005 State Budget and provision for a new rule that determines the taxation of 50% of dividends when dealing with dividends which were not subject to effective taxation (for Portuguese holding companies no taxation applies). Whenever the participation exemption applies to EU dividends, the Portuguese taxpayer has to obtain a duly certified statement from the relevant EU member State. Entities not pursuing a commercial, industrial or agricultural business activity The subsidies aimed at financing the statutory purposes of these entities are not subject to CIT even if said subsidies are not directly and immediately aimed at satisfying the statutory purposes. The gifts directly and immediately aimed at satisfying the statutory purposes of these entities are subject to but exempt from CIT. Tax Consolidation Revocation of the minimum five year period. The option to adhere to the tax consolidation regime is now solely exercised by the parent company with the subsidiaries no longer having to make similar statements. Common System of Taxation applicable to Mergers, Divisions, Transfers of Assets and Exchanges of Shares Implementation of Council Directive 2005/19/EC of 17th February Redefinition of the concept of partial division in order to safeguard that the tax neutrality regime only applies where at least one branch of activity is left at the level of the transferring company. The holding and management of stakes in companies no longer constitutes in itself a branch of activity. Broadening of the concept of exchange of shares to include the situations whereby the acquiring company already has the majority of the voting rights of the acquired company. Applicability of the tax neutrality regime to the situations whereby a Portuguese permanent establishment of an EU company is transferred to a Portuguese company and subsequently dissolved. Possibility of transferring and carrying forward the tax losses in situations whereby a permanent establishment of an EU company is transferred into a Portuguese company (including mergers and divisions and not only transfer of assets). The shareholder of a company under a division procedure benefits from the tax neutrality regime if, for tax purposes, the value of its stake is allocated between the stake to be granted under the division and the stake to be kept in the transferring company. This allocation has to be made in proportion to the value of the assets transferred to the acquiring company and the value of the assets of the transferring company. Winding-up Reduction from three to two years of the tax winding-up period. Withholding Tax Exemption Dividends paid to Portuguese financial institutions only benefit from withholding tax exemption if the participation exemption requirements are satisfied (and not under the general November
3 VAT withholding tax exemption rule applicable to all types of capital income obtained by Portuguese financial institutions). Renewal of Fleets Only 20% of the capital gains made from the sale of goods vehicles of at last twelve tons, acquired prior to and with a number plate dated before 1 st October 2006 and allocated to the public or private transportation of goods are taxed. This is provided that the sale proceeds are reinvested in the acquisition of goods vehicles with a number plate dated after 1 st October 2006 and allocated to the same purpose. IAS and Financial Institutions The entities which are under the supervision of the Banco de Portugal and which are required to follow the adjusted international accounting standards (AIAS) are no longer obliged to have separate accounts, for tax purposes, under the Portuguese internal accounting policy. Therefore, the accounts prepared in accordance with the AIAS, with the adjustments imposed by the Portuguese State Budget for 2007, will be relevant for tax purposes. This change takes effect 1 January Authorisation on IAS The Government is authorised to review the Portuguese tax rules on the assessment of the tax basis in order to make them coherent with the international accounting standards. Specific guidelines have to be followed. Authorisation on Simplified Regime The government is authorised to revoke the simplified regime and to replace it with a new simplified regime, accountancy based, applicable to taxpayers who have an annual turnover equal to or lower than 250,000. Authorisation on Transfer Prices The government is authorised to create a regime of upfront binding agreements on transfer prices which bind both the taxpayers and the Portuguese tax authorities. VAT on Imports Extending the payment term period of VAT on imports. Only applicable from 1 st July Invoice The issuing of an invoice is mandatory whenever requested (even for small retailers and exempt service providers) or whenever the acquirer is a VAT taxpayer. Small Retailers Possibility of deducting inputted VAT on the lease (and not only on the acquisition) of investment assets or assets for company use. VAT Regularisation in favour of the Taxpayer Extending the term period from one to two years. 5% Rate Applicable to construction works whose aim is to refurbish properties located in legally classified urban redevelopment areas. Free Transfers of Goods and Services The free transfers of goods and services made by the entities which benefited from a gift are not November
4 subject to VAT whenever the accumulated value of the free transfers does not exceed 5% of the gift value. Municipal Tax Evaluation of Rural Property In certain circumstances there is no need for a direct evaluation of rural properties. Evaluation of Urban Property Changes to the wording and the value and factors used in evaluating urban properties (allocation, quality and comfort and antiquity factors), provision for a new evaluation factor (area adjustment criterion) and changes in the powers of the competent evaluation body to reflect the new rules. Only applicable from 1 st July Tax Rate and Off-Shore Reduction from 5% to 1% or 2% whenever the properties are held by entities located in listed tax havens. The 1% rate is for occupied properties, the 2% rate for unoccupied. Tax Rate and Municipalities For properties classified as being of public interest, relevant municipal value or cultural heritage, the respective municipality may grant a 40% reduction of the municipal tax rate for the year in question. Public Interest, Relevant Municipal Value and Cultural Heritage Exemptions Revocation of the exemptions applicable to properties classified as being of public interest, relevant municipal value or cultural heritage. The Municipal Tax exemption is granted automatically for properties classified as national monuments which were acquired with Transfer Tax exemption, to expire in the year when the property is declassified. The Portuguese tax authorities will notify all the beneficiaries of the revoked exemptions of the respective expiration, with each of them being entitled to apply within ninety days for the general Municipal Tax exemption (Municipal Tax exemption for permanent residential properties provided that the relevant requirements are satisfied and that the taxpayer in question has not been granted that exemption for the property). Refurbishment Exemptions Broadening of the concept of refurbishment for the purposes of Municipal Tax exemption. Residential Property Exemption 5% increase in the relevant tax values for the Municipal Tax exemption applicable to permanent residential properties. Where the urban properties are leased, the two exemptions per taxpayer limit does not apply. Emigrants may also benefit from Municipal Tax exemption applicable to permanent residential properties without the need to allocate the properties to their permanent residence within the standard six month period. The new regime for emigrants is established following the revocation of the ten years exemption applicable to emigrants who acquired urban properties under the special emigrants-savings regime (the present revocation safeguards November
5 the exemptions granted in the past and the possibility of granting the exemption to properties acquired before 17 th August 2006). Increase of Rents Restrictions and Exemption Revocation of the Municipal Tax exemption applicable to leased properties where legal restrictions to increase the rents apply. Transfer Tax Financial Institutions Exemption The Transfer Tax exemption applicable to financial institutions or to companies held by them in the cases of datio pro solvendo (i.e. transfer of property to settle a debt) has been limited when dealing with non-residential properties. In order to benefit from the Transfer Tax exemption for non-residential properties at least one year will have had to pass between the lack of payment and the datio pro solvendo. Furthermore, debtor and creditor cannot be related parties and the Transfer Tax exemption has to be applied for and granted by the Ministry of Finance (with a prior opinion issued by the Portuguese tax authorities). The applicability of the Transfer Tax exemption to companies held by financial institutions depends on whether the companies in question are classified as financial institutions or as financial companies. Furthermore, in the cases of datio pro solvendo where the debtor transfers a residential property the necessary authorisation from the Ministry of Finance must be obtained in advance (with a prior opinion issued by the Portuguese tax authorities) if the value exceeds 85,500 (value for 2007). Residential Property Updating of the exempt value for residential properties by approximately 2.3% (from 83,500 to 85,500). 2% updating of the various scales. Tax Rate and Off-Shore Reduction from 15% to 8% whenever the properties are acquired by entities located in listed tax havens. Tax Benefits Forfeit of Tax Benefits - Implementation of the rule under which the tax benefits are in force for a five year period, after which they will be revaluated and possibly extended. The general five year rule does not apply where a specific tax benefit rule determines otherwise, nor to pension funds, contributions made by the employers to social security regimes, pension savings funds, education savings funds, pension/education savings funds, investment funds, private equity funds, forest resources real estate funds, Municipal Tax exemptions and to the tax benefits emerging from international arrangements. The tax benefits acquired under specific tax benefit rules will remain valid and in force under the exact terms under which they were granted. The five year rule will not have the effect of extending the terms specifically stipulated in the tax benefit rules in question. November
6 Systematic The most relevant feature in terms of innovation and simplification is bringing several loose tax benefits rules and regimes under the Tax Benefits Law. The tax benefits for midland regions, companies reorganisations and patronage can now be found in the Tax Benefits Law. This bringing of several tax benefits under the Tax Benefits Law, together with the implementation of the five year rule, grants stability and certainty to decision-makers and allows well-balanced medium-term tax planning. Patronage Cash contributions exceeding 200 must be made by bank transfer, nominative cheque or direct debit so that the relevant Maecenas may be identified. Pension Funds Revocation of the Stamp Duty exemption. Contributions made to pension funds and complementary social security regimes are only deductible for Personal Income Tax purposes if they are made by (i) the taxpayer and they are not a taxable cost for business income purposes or (ii) a third party and taxed as income of the taxpayer. Pension Savings Funds, Education Savings Funds, and Pension/Education Savings Funds The contributions made after retirement cannot be deducted for Personal Income Tax purposes. Private Equity Funds Income paid on the units to non-resident entities without a permanent establishment in Portugal is exempt except if the non-resident entity is not located in a listed tax haven or held in more than 25% by Portuguese resident entities, in which case a final 10% taxation applies. The same final 10% taxation is applicable to Portuguese resident individuals who obtain the income from the units outside of a business activity. In all the other situations a withholding tax rate of 10% applies and the tax withheld will be considered as a payment on account of the final tax liability, with the taxpayer bound to include the income paid on the units within its overall income. In such cases, and where the income on the units includes dividends, a 50% deduction of the included dividends is allowed. Finally, the private equity funds regime provides for specific rules on the certification of non-residence, on statement obligations and imposes the jointly and several tax liability of the management company. Forest Resources Real Estate Funds Creation of the new tax regime applicable to Portuguese forest resources real estate funds in identical terms to the ones governing private equity funds. The eligibility conditions of this new regime include, among others, the allocation of at least 75% of the fund s assets to the activity of forest resources under a specific and legally approved Forest Management Action Plan or subject to official certification by the relevant authorities. Employment Incentives Broadening of the tax benefit applicable to the net creation of working places so that it may also benefit Portuguese resident individuals that pursue an accountancy-based business activity. November
7 The tax benefit is also applicable if the new working place is created for long term unemployed. Clarification of the relevant concepts for the purposes of the tax benefit, notably, the concepts of youth, long term unemployment, eligible costs and net creation of working places. Family members of the employer are not eligible for the purposes of the tax benefit. The present benefit is not cumulative with other tax benefits of a similar nature or with other incentives which promote employment. The tax benefit is significantly limited as it will only be granted once in respect of the same employee, even if dealing with different employers. This change takes effect for tax periods beginning after 1 January Participation Exemption and Africa Broadening of the participation exemption to dividends paid by companies residing in African countries which have Portuguese as their official language. The eligibility conditions include, among others, a minimum stake of 25% held for a minimum two year period. Furthermore, the regime does not apply to dividends resulting from passive income, i.e., royalties, capital gains, income on securities, non-african property income or non-african insurance or financial income. Capital Gains and Privatization Revocation of the exemption applicable to capital gains made by public owned companies from the privatisation processes. Cooperatives Revocation of part of the tax benefits applicable to cooperatives and to their members. The revoked benefits include Personal Income Tax deductions, Stamp Duty exemptions and tax exemptions under reorganisations. Creation of rule that provides for penalties in the cases where a Portuguese resident individual who benefited from a Personal Income Tax deduction does not comply with the cooperatives regime on repayment of contributions. Mortgage-Back VAT and Stamp Duty exemption on fees for the management and assignment of mortgage-backed credits made under the legal regime of mortgage-backed bonds. Real Estate Funds Municipal Tax and Transfer Tax Revocation of the full Municipal Tax and Transfer Tax exemptions if dealing with close-ended Portuguese real estate funds with private placements, whose participation units are held by non-qualified investors. These type of Portuguese real estate funds will pay Municipal Tax and Transfer Tax at half of the regular rates (maximum Municipal Tax of 0.4%, maximum Transfer Tax of 3.25%). November
8 Author: Tânia de Almeida Ferreira Contacts: Patrick Dewerbe Ricardo Reigada Pereira Lisbon Avenida Fontes Pereira de Melo, 14-15º Lisbon, Portugal Tel: (351) Fax: (351) This publication is intended merely to highlight issues and not to be comprehensive, nor to provide legal advice. Should you have any questions on issues reported here or on other areas of law, please contact one of your regular contacts at Linklaters, or contact the editors. Linklaters. All Rights reserved 2006 Please refer to for important information on the regulatory position of the firm. We currently hold your contact details, which we use to send you newsletters such as this and for other marketing and business communications. We use your contact details for our own internal purposes only. This information is available to our offices worldwide and to those of our associated firms. If any of your details are incorrect or have recently changed, or if you no longer wish to receive this newsletter or other marketing communications, please let us know by ing us at 8
Tax Flash CIT Reform Proposal
www.pwc.pt Tax Flash CIT Reform Proposal Cornerstones of this reform: simplification of tax compliance obligations, reduction of tax disputes, as well as a the intention to progressively reduce the corporate
More informationReal Estate Investment: Main Tax Issues
Real Estate Investment: Main Tax Issues 1 All the lawyers know what s happening on the case and work really well as a team. It sets them apart from others in the market. Client reference from Chambers
More informationA body corporate which is not an OEIC (i.e. not openended).
REITs. Quick Guide: UK REIT Following the enactment of the Finance Act 2006, the development of the UK REIT is now in its final stages ready for a launch date of 1 January 2007. From this date, existing
More informationInternational Tax Croatia Highlights 2018
International Tax Croatia Highlights 2018 Investment basics: Currency Croatian Kuna (HRK) Foreign exchange control The Foreign Exchange Act regulates domestic and foreign currency transactions. Legal entities,
More informationVAT in the European Community APPLICATION IN THE MEMBER STATES, FACTS FOR USE BY ADMINISTRATIONS/TRADERS INFORMATION NETWORKS ETC.
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION Indirect Taxation and Tax administration VAT and other turnover taxes Brussels, October 2010 TAXUD/C/1 VAT in the European Community APPLICATION
More informationCHILE GLOBAL GUIDE TO M&A TAX: 2017 EDITION
CHILE 1 CHILE INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? On 2014, a tax reform was enacted in Chile whose provisions
More informationTax Guide 2018 PLMJ TAX
Tax Guide 2018 PLMJ TAX Tax Guide 2018 1 - PERSONAL INCOME TAX (PIT) 1.1 - APPLICATION OF PIT AND TAX RESIDENCE Personal income tax (PIT) in Portuguese, Imposto Sobre o Rendimento das Pessoas Singulares
More informationInternational Tax Albania Highlights 2018
International Tax Albania Highlights 2018 Investment basics: Currency Albanian Lek (ALL) Foreign exchange control There are no foreign exchange controls; repatriation of funds may be made in any currency.
More informationCorporate Structures for Internationally Mobile People
Corporate Structures for Internationally Mobile People Panama City, Panama October 2016 2016 LUGNA Topics to consider Should I use a corporate vehicle to trade? Is my offshore corporate vehicle appropriate?
More informationInternational Tax South Africa Highlights 2018
International Tax South Africa Highlights 2018 Investment basics: Currency South African Rand (ZAR) Foreign exchange control Exchange control is administered by the South African Reserve Bank, which has
More informationEurope's Best Kept Secret
www.pwc.pt Why Portugal is your top tax choice 2012 Leendert Verschoor Portugal Among the 20 most visited countries in the world Portuguese language is spoken by about 230 million people around the world
More informationInternational Tax Portugal Highlights 2018
International Tax Portugal Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control Portugal does not have exchange controls and there are no restrictions on the import or export
More informationPORTUGAL AS A PLATFORM OF INVESTMENT
PORTUGAL AS A PLATFORM OF INVESTMENT 10-05-2017 PORTUGAL AS A PLATFORM OF INVESTMENT 1 8 Wide Double Tax Convention Network Non Habitual Residents Golden Visa 2 Participation Exemption 7 Real Estate 3
More informationT H E C O R P O R A T E I N C O M E T A X R E F O R M : T A X S I M P L I F I C A T I O N A N D I N V E S T M E N T P R O M O T I O N
i T A X INFORMATION N. 1 5 J u ly 2013 T H E C O R P O R A T E I N C O M E T A X R E F O R M : T A X S I M P L I F I C A T I O N A N D I N V E S T M E N T P R O M O T I O N TABLE OF CONTENTS I. A B S T
More informationTHE TAXATION OF PRIVATE EQUITY IN ITALY
THE TAXATION OF PRIVATE EQUITY IN ITALY 1 Index 1 INTRODUCTION 3 1.1 Tax environment 5 1.2 Taxation system 5 1.2.1 Corporate Income Tax IRES 6 1.2.2 Regional Production Tax IRAP 9 2 TAXATION OF ITALIAN
More informationTAX CARD 2016 ROMANIA
ROMANIA TAX CARD TAX CARD 2016 ROMANIA Table of Contents 1. Individuals 1.1 Personal Income Tax 1.1.1 Tax Rates 1.1.2 Taxable Income 1.1.3 Exempt Income 1.1.4 Deductible Expenses/Allowances 1.2 Social
More informationInternational Tax Israel Highlights 2018
International Tax Israel Highlights 2018 Investment basics: Currency New Israeli Shekel (NIS) Foreign exchange control There are no foreign currency restrictions. Accounting principles/financial statements
More informationLeasing taxation Estonia
2012 KPMG Baltics OÜ, an Estonian limited liability company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss
More informationAustria. Clemens Philipp Schindler and Martina Gatterer. Schindler Attorneys
AUSTRIA Austria Clemens Philipp Schindler and Martina Gatterer Acquisitions (from the buyer s perspective) 1 Tax treatment of different acquisitions What are the differences in tax treatment between an
More informationInternational Tax Morocco Highlights 2018
International Tax Morocco Highlights 2018 Investment basics: Currency Moroccan Dirham (MAD) Foreign exchange control Transactions in foreign currency generally are not restricted, but there are some administrative
More informationGlobal Stock Options. PORTUGAL Morais Leitão, Galvão Teles, Soares da Silva & Associados
Global Stock Options PORTUGAL Morais Leitão, Galvão Teles, Soares da Silva & Associados CONTACT INFORMATION: Luísa Soares da Silva Eduardo Paulino Morais Leitão, Galvão Teles, Soares da Silva & Associados
More informationBELGIUM GLOBAL GUIDE TO M&A TAX: 2018 EDITION
BELGIUM 1 BELGIUM INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? A major corporate income tax reform has been published
More informationTax data card 2018/2019
Tax data card 2018/2019 1 Contents 1 Individuals and trusts 4 Companies 5 Capital allowances 6 Capital gains tax 7 Tax Administration Act penalties 8 Value-added tax 8 Other taxes, duties & levies 10 Exchange
More informationJapan. Country M&A Team Country Leader ~ Kazuya Miyakawa Hirohiko Takamura Jack Bird Alfred Zencak
Japan Country M&A Team Country Leader ~ Kazuya Miyakawa Hirohiko Takamura Jack Bird Alfred Zencak Mergers & Acquisitions Asian Taxation Guide 2008 Japan March 2008 PricewaterhouseCoopers 99 Name Designation
More informationFINLAND GLOBAL GUIDE TO M&A TAX: 2017 EDITION
FINLAND 1 FINLAND INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? The most relevant recent developments in Finland relate
More informationTURKEY GLOBAL GUIDE TO M&A TAX: 2017 EDITION
TURKEY 1 TURKEY INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? Recently, there are no tax developments in Turkey which
More informationFOREWORD. Cameroon. Services provided by member firms include:
2016/17 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
More informationPortugal. Chapter 38. Pedro Gorjão Henriques and Rui de Oliveira Neves Morais Leitão, J Galvão Teles & Associados
Chapter 38 Portugal Pedro Gorjão Henriques and Rui de Oliveira Neves Morais Leitão, J Galvão Teles & Associados 1 Form What form do business combinations take? Portuguese law defines several ways for companies
More informationInternational Tax Greece Highlights 2018
International Tax Greece Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control Capital controls are in force and certain limitations still apply on bank withdrawals and bank transfers
More informationARGENTINA GLOBAL GUIDE TO M&A TAX: 2017 EDITION
ARGENTINA 1 ARGENTINA INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? On 23 September 2013, the Income Tax Law was amended.
More informationCountry Tax Guide.
Country Tax Guide www.bakertillyinternational.com Facts and figures as presented are correct as of 18 August 2014. Corporate Income Taxes Resident companies, defined as those companies which are incorporated
More informationLaw regarding the Fiscal Code. Law no. 227/2015 published in the Official Gazette no. 688 of 10 September 2015
21 September 2015 Law regarding the Fiscal Code Law no. 227/2015 published in the Official Gazette no. 688 of 10 September 2015 Starting with 1 January 2016, Law no. 227/2015 regarding the Fiscal Code
More informationMauritius Taxes Overview
Mauritius Taxes Overview Mauritius personal Income Tax Mauritius personal tax rate is a flat 15%. As from 1 January 2010, the fiscal year will be on a calendar year basis. Income Tax is payable by residents
More informationBASIC BANK ACCOUNTS. Lisbon,
BASIC BANK ACCOUNTS Lisbon, 2017 www.bportugal.pt http://clientebancario.bportugal.pt BASIC BANK ACCOUNTS 5th reissue, August 2017 Banco de Portugal Av. Almirante Reis, 71 1150-012 Lisboa www.bportugal.pt
More informationInternational Tax Latvia Highlights 2019
International Tax Updated January 2019 Investment basics: Currency Euro (EUR) Foreign exchange control No Accounting principles/financial statements National standards (following IAS) and IFRS. Financial
More informationStandard RA4.6. Reporting of non-performing and zerointerest. Regulations and guidelines
Standard RA4.6 Reporting of non-performing and zerointerest assets Regulations and guidelines THE FINANCIAL SUPERVISION AUTHORITY until further notice assets J. No. 2/120/2006 2 (2) TABLE OF CONTENTS 1
More informationFOREWORD. Tunisia. Services provided by member firms include:
FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are there
More informationSPECIAL TAX REGIMES IN PORTUGAL: THE NON-HABITUAL TAX RESIDENT REGIME
SPECIAL TAX REGIMES IN PORTUGAL: THE NON-HABITUAL TAX RESIDENT REGIME Introduction In recent years, Portugal introduced several measures that aim to promote foreign investment and the relocation of individuals
More informationInternational Tax Thailand Highlights 2018
International Tax Thailand Highlights 2018 Investment basics: Currency Thai Baht (THB) Foreign exchange control Repatriation payments may not be made in THB, but may be made in any other currency. An exception
More informationTax Law Newsletter. December New draft tax bill
Tax Law Newsletter December 2012 New draft tax bill New Draft tax bill Introduction On December 13 th, the Greek Government submitted to the Parliament for enactment a draft bill which brings several important
More informationTaxation of cross-border mergers and acquisitions
Taxation of cross-border mergers and acquisitions Colombia kpmg.com/tax KPMG International Colombia Introduction Cross-border merger and acquisition (M&A) activity in Colombia has been increasing in recent
More informationInternational Tax Greece Highlights 2019
International Tax Updated January 2019 Recent developments: For the latest tax developments relating to Greece, see Deloitte tax@hand. Investment basics: Currency Euro (EUR) Foreign exchange control Restrictions
More informationInternational Tax Slovenia Highlights 2018
International Tax Slovenia Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control Bank accounts may be held and repatriation payments made in any currency. Accounting principles/financial
More informationTHE NETHERLANDS GLOBAL GUIDE TO M&A TAX: 2017 EDITION
THE NETHERLANDS 1 THE NETHERLANDS INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? There are various relevant developments
More informationSWITZERLAND GLOBAL GUIDE TO M&A TAX: 2017 EDITION
SWITZERLAND 1 SWITZERLAND INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? Swiss tax authorities scrutinise more closely
More information1. What are recent tax developments in your country which are relevant for M&A deals? CFC
Poland General Poland 1. What are recent tax developments in your country which are relevant for M&A deals? CFC As of 1 January 2015, CFC regulations were implemented in Poland. Under new rules income
More informationRomania. Structure and development of tax revenues. Romania. Table RO.1: Revenue (% of GDP)
Structure and development of tax revenues Table RO.1: Revenue (% of GDP) 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 I. Indirect taxes 11.7 12.8 12.7 12.5 11.8 10.8 11.9 13.0 13.2 12.8 VAT 6.6 8.0
More informationInternational Tax Spain Highlights 2018
International Tax Spain Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control No, but the government requires prior notification of certain capital movements under anti-money
More informationROMANIA GLOBAL GUIDE TO M&A TAX: 2018 EDITION
ROMANIA 1 ROMANIA INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? The new Romanian Fiscal Code, in force starting 1 January
More informationINTRODUCTION 2019 TAX PLAN
2019 DUTCH TAX PLAN INTRODUCTION During Budget Day (18 September 2018) in the Netherlands a number tax plans were published. Please find below a selection of the most relevant proposals PERSONAL INCOME
More informationNon-habitual residents in Portugal FRAMEWORK AND CONDITIONS
Non-habitual residents in Portugal FRAMEWORK AND CONDITIONS 1 The lawyers provide an excellent level of attention to the client and demonstrate a superb knowledge of the market and the latest legislation.
More informationPAYROLL CONTRIBUTIONS in force on 1 st January Contribution Employer (rate %) Social security contribution
page Tax Newsletter No. 12 / 2005 Str. Brezoianu, Nr. 36, Sector 1, Bucuresti Tel: +40 (0)21 313 70 31 Tel: +40 (0)745 20 27 39 Fax:+40 (0)21 313 70 68 Contents: PAYROLL Contributions 2006 NEW software
More informationSwitzerland. Investment basics
Switzerland Diego Weder Director Tel: +1 212 492 4432 diweder@deloitte.com Investment basics Currency Swiss Franc (CHF) Foreign exchange control restrictions are imposed on the import or export of capital.
More informationCYPRUS GLOBAL GUIDE TO M&A TAX: 2017 EDITION
CYPRUS 1 CYPRUS INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? The most recent developments which are relevant to M&A
More informationSOUTH AFRICA GLOBAL GUIDE TO M&A TAX: 2017 EDITION
SOUTH AFRICA 1 SOUTH AFRICA INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? In the 2016 Budget Review, tax avoidance
More informationIRS Provides Initial Guidance under Foreign Accounts Legislation.
September 2010 IRS Provides Initial Guidance under Foreign Accounts Legislation. On August 27, 2010, the US Internal Revenue Service ( IRS ) released Notice 2010-60 (the Notice ), which contains guidance
More informationInternational Tax Finland Highlights 2018
International Tax Finland Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control No Accounting principles/financial statements Finnish GAAP/IFRS applies. Financial statements must
More informationFinland. Structure and development of tax revenues. National tax systems: Structure and recent developments. Table FI.1: Tax Revenue (% of GDP)
Finland Structure and development of tax revenues Table FI.1: Tax Revenue (% of GDP) 00 003 004 005 006 007 008 009 010 011 01 013 Ranking Revenue (billion euros) A. Structure by type of tax Indirect taxes
More informationRomania's New Fiscal Code
FEATURED ARTICLES ISSUE 152 OCTOBER 8, 2015 Romania's New Fiscal Code by Angela Rosca, Taxand Contact: angela.rosca@taxhouse.ro, Tel. +40 21 316 06 45 Law No. 227/2015 was published in the Offi cial Gazette
More informationTERMS AND CONDITIONS OF THE NOTES
TERMS AND CONDITIONS OF THE NOTES The following are the Terms and Conditions of the Notes which will be applicable to each Note (as defined below). Each Note is one of a series of Notes issued by Sociedade
More informationFINANCE BILL 2016 LIST OF ITEMS PART 1 MEASURES ANNOUNCED IN THE BUDGET PART 2 FURTHER MEASURES INCLUDED IN THE FINANCE BILL
FINANCE BILL 2016 LIST OF ITEMS PART 1 MEASURES ANNOUNCED IN THE BUDGET PART 2 FURTHER MEASURES INCLUDED IN THE FINANCE BILL 1 PART 1 - MEASURES ANNOUNCED IN THE BUDGET INCOME TAX... 4 SECTIONS 2 TO 4
More informationChapter 12. Tax Administration. 94 PwC
Chapter 12 Tax Administration 94 PwC The government departments responsible for the administration of the main tax laws are: The Inland Revenue Department for income tax and stamp duty The Value Added
More informationJAPAN. Country M&A Team Country Leader ~ Kan Hayashi Shinji Ishiguro Alfred Zencak. 105 PricewaterhouseCoopers
105 PricewaterhouseCoopers JAPAN Country M&A Team Country Leader ~ Kan Hayashi Shinji Ishiguro Alfred Zencak 106 PricewaterhouseCoopers Name Designation Office Tel Email Kan Hayashi Partner +813 5251 2877
More informationPROSPECTUS SUPPLEMENT Luxottica Group S.p.A. (incorporated with limited liability in the Republic of Italy)
PROSPECTUS SUPPLEMENT Luxottica Group S.p.A. (incorporated with limited liability in the Republic of Italy) 2,000,000,000 Euro Medium Term Note Programme unconditionally and irrevocably guaranteed by Luxottica
More information21% 21% The Regional Finance Law provides that RAM can set a rate 20% lower than that applicable in Mainland Portugal 2.
01 CIT 1 21% 21% The Regional Finance Law provides that RAM can set a rate 20% lower than that applicable in Mainland Portugal 2. 5% ; 2.5% (IFTZ 8 if some conditions are met) 80% of exemption of surtax
More informationHeadquarter Jurisdictions Around the World: A Comparison
Headquarter Jurisdictions Around the World: A Comparison 2017 Austria Belgium Cyprus Dubai Hong Kong Ireland Luxembourg The Netherlands Portugal Singapore Spain Switzerland United Kingdom Headquarter jurisdictions
More informationVAT in the European Community APPLICATION IN THE MEMBER STATES, INFORMATION FOR USE BY: ADMINISTRATIONS/TRADERS INFORMATION NETWORKS, ETC.
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION Indirect Taxation and Tax administration VAT and other turnover taxes Brussels, October 2010 TAXUD/C/1 VAT in the European Community APPLICATION
More informationNewsletter. Integrated Legal Consultants. Edition 1 January Editor s Note
Edition 1 January 2016 Newsletter Editor s Note (ILC) was founded in April 2007, in Accra, Ghana, to offer dedicated and innovative corporate legal services while ensuring that the Ghanaian and West African
More informationIn accordance with a decision of the Parliament, the following is enacted:
[UNOFFICIAL TRANSLATION MINISTRY OF ECONOMIC AFFAIRS AND EMPLOYMENT 2017] Accounting Act 1336/1997 In accordance with a decision of the Parliament, the following is enacted: Chapter 1 General provisions
More informationPortugal (Azores and Madeira)
Portugal (Azores and Madeira) University of Deusto (Bilbao) 12-14 December 2006 Ricardo Henriques da Palma Borges ricardo.palma.borges@gmail.com 1 2 Regional Tax Regulation in Portugal after the ECJ Azores
More informationGreece. Capital city: Athens. GDP/capita 2015: USD Telephone code: +30. Language: Greek. National day: March 25th and october 28th
Greece ALBANIA Capital city: Athens Superficy: 131 957 km 2 Population: 10 820 M. Language: Greek Political system: Parliamentary republic GDP/capita 2015: USD 18 002 Currency: Euro ISO Code: GRC Telephone
More informationStructural tax reforms approved after new law ratified by the Greek Parliament
Greece Tax News July 11, 2018 Structural tax reforms approved after new law ratified by the Greek Parliament The Greek parliament ratified Law 4549/2018 on 14 June 2018. The law includes changes to the
More informationARTICLES OF ASSOCIATION OF SPECIAL CLOSED-END TYPE REAL ESTATE INVESTMENT COMPANY INVL BALTIC REAL ESTATE
ARTICLES OF ASSOCIATION OF SPECIAL CLOSED-END TYPE REAL ESTATE INVESTMENT COMPANY INVL BALTIC REAL ESTATE The Articles of Association were signed in Vilnius on [ ] [ ] [ ] Authorised person: [ ] [ ] 1
More informationEU Commission approves enhancements to Madeira International Business Center Tax Regime
3 September 2013 EU Commission approves enhancements to Madeira International Business Center Tax Regime Executive summary On 2 July 2013, the EU Commission issued a decision allowing Portugal to increase
More informationPortugal Taxation of Short-Term Lettings by Non-Resident Landlords March 2018
Portugal Taxation of Short-Term Lettings by Non-Resident Landlords March 2018 Contents Disclaimer... 1 Overview... 2 A word of caution: associação em participação... 2 The Red Tape... 3 Income Tax... 3
More informationInternational Tax Italy Highlights 2018
International Tax Italy Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control There are no foreign exchange controls or restrictions on repatriating funds. Residents and nonresidents
More informationCorporate Social Responsibility under the New Companies Act.
April 2014 Corporate Social Responsibility under the New Companies Act. 1 Introduction The recently enacted Companies Act, 2013 seeks to encourage large companies to invest in developmental activities
More information1. What are recent tax developments in your country which are relevant for M&A deals?
Colombia General Colombia 1. What are recent tax developments in your country which are relevant for M&A deals? Recent tax reforms have recognised several corporate reorganisations as tax neutral transactions.
More informationInternational Tax Lithuania Highlights 2017
International Tax Lithuania Highlights 2017 Investment basics: Currency Euro (EUR) Foreign exchange control No Accounting principles/financial statements IAS and IFRS, or Business Accounting Standards
More informationFOREWORD. Gambia. Services provided by member firms include:
FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are there
More informationGERMANY GLOBAL GUIDE TO M&A TAX: 2017 EDITION
GERMANY 1 GERMANY INTERNATIONAL DEVELOPMENTS 1. WHAT ARE RECENT TAX DEVELOPMENTS IN YOUR COUNTRY WHICH ARE RELEVANT FOR M&A DEALS AND PRIVATE EQUITY? Germany has recently seen some legislative developments
More informationPORTUGAL AS A PLATFORM OF INVESTMENT. January 2017
PORTUGAL AS A PLATFORM OF INVESTMENT January 2017 1 - CONTEXTUALIZATION ONTEXTUALIZATION 1 PORTUGAL AS AN INVESTMENT PLATFORM Portugal has been implementing several tax measures, with an increasing tone
More informationInternational Tax Korea Highlights 2018
International Tax Korea Highlights 2018 Investment basics: Currency South Korean Won (KRW) Foreign exchange control Controls exist, but gradually have been liberalized. Foreign loans in excess of a specified
More informationFOREWORD. Gambia. Services provided by member firms include:
2016/17 FOREWORD A country's tax regime is always a key factor for any business considering moving into new markets. What is the corporate tax rate? Are there any incentives for overseas businesses? Are
More informationNon-habitual residents in Portugal FRAMEWORK AND CONDITIONS
Non-habitual residents in Portugal FRAMEWORK AND CONDITIONS 1 The lawyers provide an excellent level of attention to the client and demonstrate a superb knowledge of the market and the latest legislation.
More informationTax Calendar A summary of the main regular tax obligations arising for companies and individuals
www.pwc.pt/tax 2018 Tax Calendar A summary of the main regular tax obligations arising for companies and individuals A PwC Due to its general nature, this publication does not cover all existing obligations,
More information1. What are recent tax developments in your country which are relevant for M&A deals?
Turkey General Turkey 1. What are recent tax developments in your country which are relevant for M&A deals? Recently, there are no tax developments in Turkey which are relevant for M&A deals. The regulation
More informationVAT Tax Evasion. Measures undertaken by the Portuguese Government. The Brussels Tax Forum th of November, 2013
VAT Tax Evasion Measures undertaken by the Portuguese Government The Brussels Tax Forum 2013 18 th of November, 2013 Agenda European context Measures undertaken by the Portuguese Government to curb tax
More informationUK REIT Summary Structure and Investment Criteria
UK REIT Summary Structure and Investment Criteria The following table is intended to provide a brief summary of how the Government s new thinking on a UK REIT compares with last year s recommendations
More informationInternational Tax Luxembourg Highlights 2018
International Tax Luxembourg Highlights 2018 Investment basics: Currency Euro (EUR) Foreign exchange control No Accounting principles/financial statements Luxembourg GAAP/IFRS. Financial statements must
More informationTax returns, self-assessments and annual summaries January 2015
Circular 1/ 2015 Tax returns, self-assessments and annual summaries January 2015 Barcelona, 7 January 2015 Dear Client, This Circular is designed to provide you with information with the Spanish tax filing
More informationNEW END-OF-YEAR TAX LEGISLATION (2017) AMENDMENTS TO THE REGULATIONS ON A NUMBER OF TAXES
COMMENTARY TAX 1-2018 JANUARY 2018 NEW END-OF-YEAR TAX LEGISLATION (2017) AMENDMENTS TO THE REGULATIONS ON A NUMBER OF TAXES The Official State Gazette of December 30, 2017 published Royal Decree-Law 20/2017,
More informationMexico. Investment basics
Mexico Josemaria Cabanillas Director Tel: +1 718 508 6804 jmcabanillas@deloitte.com Eduardo Rueda Senior Manager Tel: +1 212 492 4765 eruedaherrera@deloitte.com Investment basics Currency Mexican Peso
More informationVALUE ADDED TAX COMMITTEE (ARTICLE 398 OF DIRECTIVE 2006/112/EC) WORKING PAPER NO 933
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION Indirect Taxation and Tax administration Value added tax taxud.c.1(2017)6142196 EN Brussels, 8 November 2017 VALUE ADDED TAX COMMITTEE
More informationThe Canary Islands An European Business Hub
www.pwc.es The Canary Islands An European Business Hub Overview The Canary Islands Special Fiscal Regime has been approved by the EU Authorities -GBL The Canary Islands have the strongest and safest group
More informationTax & Legal Alert PwC Hungary Issue 580 July 2017
Tax & Legal Alert PwC Hungary Issue 580 July 2017 On 13 June 2017, the Parliament passed Act LXXVII of 2017 on the amendment of various tax laws. This newsletter summarises the most important changes proposed
More information2017 Financial Statements
2017 Financial Statements Annual Report 2017 page 2 CTT-CORREIOS DE PORTUGAL, S.A. CONSOLIDATED AND INDIVIDUAL STATEMENT OF FINANCIAL POSITION AS AT 31 DECEMBER 2017 AND 31 DECEMBER 2016 Euros NOTES 31.12.2017
More informationTax data card 2013/2014
Tax data card 2013/2014 Contents Interest rates 1 Individuals and trusts 1 Companies 4 Capital allowances 5 Capital gains tax 6 Tax Administration Act penalties 7 Value-added tax 8 Other taxes, duties
More informationTax Law Newsletter. January 2013
Tax Law Newsletter January 2013 New Tax Law 4110/2013 New Tax Law 4110/2013 Introduction Law 4110/2013 in respect to Provisions on income taxation, other issues relating to the Ministry of Finance and
More informationInternational Tax Japan Highlights 2019
International Tax Updated January 2019 Recent developments: For the latest tax developments relating to Japan, see Deloitte tax@hand. Investment basics: Currency Japanese Yen (JPY) Foreign exchange control
More information