RPBA Presentation - Madeira Free Zone - Updated: 18.10.2022

Madeira Free Zone
Ricardo da Palma Borges
ricardo@rpba.pt
www.rpba.pt

Overview
PAGE:
▪ Introduction 3
▪ The Critical Issues 20
▪ Taxation of Madeira Free Zone (MFZ) Companies 38
▪ Madeira’s Practical Structures 60

Introduction
3
▪ Main Taxes
▪ Business Climate in Madeira
▪ Value Added Tax
▪ Personal Income Tax
▪ Corporate Income Tax
3

4
How to spell Madeira
(frequent client answers)
Madiera NO
Maderia NO
Madieria NO
Maidera NO
Maideira NO
Maideria NO
Madeira YES

5
Main Taxes in Portugal
Value Added Tax (VAT) Imposto sobre o Valor Acrescentado
Personal Income Tax (PIT) Imposto sobre o Rendimento das Pessoas Singulares
Corporate Income Tax (CIT) Imposto sobre o Rendimento das Pessoas Colectivas
Social Security (SS) Segurança Social
Stamp Tax (ST) Imposto do Selo
Property Transfer Tax (PTT) Imposto Municipal sobre as Transmissões Onerosas de Imóveis
Property Ownership Tax (POT) Imposto Municipal sobre Imóveis
Gift and Inheritance Tax (GIT)
Currently Stamp Tax (individuals) or Corporate Income Tax (corporate
entities)

6
Main Benefits of the MFZ under the 2015-2027
regime
i. Low CIT taxation on foreign source income derived from activities carried out in the institutional scope of the MFZ by
entities settled therein – tax rate of 5% applicable between 2015 and 2027.
ii. CIT and PIT exemption on royalties and service fees paid by entities settled in the MFZ to non-residents.
iii. CIT exemption on interest paid to non-residents by entities settled in the MFZ on loans contracted to finance the
investments and regular activities of such entities.
iv. 80% reduction of Stamp Tax, POT and PTT (doubtful if this limitation applies to companies licensed under previous
regimes).
v. CIT and PIT exemption on dividends distributions to non-resident shareholders.
vi. CIT and PIT exemption on interest and other forms of compensation for liquidity supplies to non-resident
shareholders.

7
Main Features of the Portuguese CIT
i. 100% dividend exclusion applicable to dividends from Portuguese, EU/EEA and Third State subsidiaries.
ii. Underlying tax credit for non-exempt dividends.
iii. 100% exclusion for capital gains on shares and related equity instruments on Portuguese, EU/EEA and Third State
subsidiaries.
iv. 50% exclusion for capital gains on most fixed assets (excluding shares) via rollover relief.
v. 85% exclusion of income generated from covered intellectual property rights (patent box regime).
vi. Exemption method available for foreign permanent establishment (“PE”) income.
vii. Exemption for capital gains on Portuguese shares by Portuguese, EU/EEA and Third State parent companies.
viii. Exemption for dividends distributed by Portuguese companies to Portuguese, EU/EEA and Third State parent companies.
All these general features may be enjoyed by MFZ entities in addition to the specific benefits applicable therein.

8
Business Climate in Madeira
▪ Strong Political Stability.
▪ Excellent Climate (16ºC winter - 22ºC summer, on average).
▪ Full EU Membership (including freedom from Exchange Controls, access to the Parent-Subsidiary Directive, the
Banking and Insurance Directives and the EU shipping cabotage).
▪ Access to Double Tax Treaty network (with limitations in the cases of USA, Brazil, Canada, Spain, Ukraine).
▪ Access to multiple EU tax Directives (Parent-Subsidiary Directive; Interest & Royalties Directive; Mergers
Directive).
▪ Waived from the EU Code of Conduct and the OECD Harmful Tax Competition assessments, and not blacklisted by
the FATF, the FSF, the OECD and many countries.
▪ Limited Tax Holiday and access to EU and Portuguese subsidies.

9
Value Added Tax
Mainland Portugal:
Madeira (even outside the
MFZ):
Ordinary 23% Ordinary 22%
Reduced I 6% Reduced I 5%
Reduced II 13% Reduced II 12%

10
Personal Income Tax in Mainland (2022)
Minimum rate (for income up to € 7.116) 14,5%
Marginal rate (for income over € 7.116 up to € 10.736) 23%
Marginal rate (for income over € 10.736 up to € 15.216) 26,50%
Marginal rate (for income over € 75.009) 48%
Additional solidarity rate (for income over € 80.000 up to € 250.000) 2,5%
Additional solidarity rate (for income over € 250.000) 5%

11
Personal Income Tax in Madeira (2022)
Minimum rate (for income up to € 7.116) 10,15%
Marginal rate (for income over € 75.009) 47,52%
Additional solidarity rate (for income over € 80.000 up to € 250.000) 2,5%
Additional solidarity rate (for income over € 250.000) 5%

12
Corporate Income Tax (2022)
Mainland Portugal and Madeira, outside MFZ:
CIT rates (Standard / Small or Medium Enterprises)
21% Mainland
Exception for SMEs: 17% rate
applies to the first €25.000
of taxable income
14,7% Madeira
Exception for SMEs: 11,9%
rate applies to the first
€25.000 of taxable income
Municipal surcharge (Maximum 1,5% on taxable income)
1,5%
22,5% Mainland 16,2% Madeira
State/Regional surcharge on income from
€ 1.500.000 up to € 7.500.000
3% Mainland 2,1% Madeira
State/Regional surcharge on income from
€ 7.500.000 up to € 35.000.000
5% Mainland
3,5% Madeira
State/Regional surcharge on income above
€ 35.000.000
9% Mainland 6,3% Madeira

13
MFZ:
▪ Activity:
− Industrial / Shipping / Services: 5%.
− Financial: no licenses issued since 1 January 2001; currently outside of the institutional scope.
▪ No Municipal surcharge on exempt income;
▪ Income taxable at the reduced 5% rate is liable to Municipal surcharge at a rate of up to 1,5% of the CIT due
depending on the municipality but only on 20% of the taxable income (2015-2027);
▪ Income taxable at the standard CIT rates is liable to Municipal surcharge at a rate of up to 1,5% of the CIT due
depending on the municipality.
▪ Income taxable at the reduced 5% rate (2015-2027) is liable to 20% of the standard Regional surcharge rates;
▪ Income taxable at the standard rate is liable to Regional surcharge at the rates in force in Madeira outside MFZ.

14
MFZ:
▪ The taxable income of companies licensed to operate in the industrial free zone of Madeira is reduced in 50% if any two of the
following is verified:
a) The company contributes to the modernization of the regional economy, namely through technological innovation of
products and manufacturing processes or business models;
b) The company contributes to the diversification of the regional economy, namely through the development of new high
value-added activities;
c) The company promotes the hiring of highly qualified human resources;
d) The company contributes to the improvement of environmental conditions;
e) The company creates at least 15 jobs, which must be maintained for a minimum period of five years.

15
MFZ 5% rate – 2015 regime requirements
▪ Activity requirement: start of activity within 6 months (international services) or one year (industrial or
shipping) from the date of the license.
▪ Eligibility requirement:
i. 1-5 jobs in the first six months of activity + minimum investment to be performed in the first two years of activity;
or
ii. 6 or more jobs in the first six months of activity.
Job creation Minimum Investment in assets
Taxable income enjoying the
reduced rate
1 - 2 € 75,000 € 2.73 million
3 - 5 € 75,000 € 3.55 million
6 - 30 - € 21.87 million
31 - 50 - € 35.54 million
51 - 100 - € 54.68 million
over 100 - € 205.5 million

16
The job creation requirement
▪ The taxable income limits enjoying the reduced rate (see slide 14) are determined according to the number of jobs
that the beneficiary entities maintain in each fiscal year, having the following as reference:
i. The number of jobs is determined by reference to the number of people earning employment income paid by a licensed
entity, provided that the employees reside for tax purposes in Madeira or, if not, exercise their activity there or are
employees or crew members of ships or recreational craft registered in the International Shipping Register of Madeira.
ii. Open-ended, part-time or intermittent employees are considered in proportion to full-time employees in a comparable
situation, measured in number of annual work units (unit of measurement equivalent to the work of a full-time person done
in a year measured in hours (1 AWU = 240 working days at 8 hours a day).
iii. The following are excluded from the calculation of the number of jobs:
a. Employees assigned by temporary work agencies, in relation to the respective user entities;
b. Employees on occasional assignment regime, in relation to the assignee entity;
c. Employees under a multi-employer regime, when the employer representing the rest in the employment relationship is not
licensed in the MFZ.

17
The € 75,000 minimum investment requirement
▪ Applicable only in the case of creation of less than 6 jobs in the first six months of activity.
▪ In the acquisition of “fixed tangible or intangible assets”. In the past, according to an Opinion of
the Regional Director of Finance in Madeira, as per the Portuguese Accounting Normalization
System (SNC), all assets included in the accounting class “Investments”, including financial
investments, qualified as fixed “corporeal or incorporeal” assets, which was the old terminology of
the tax rule. Nowadays, a narrower criterion and more accurate wording excludes financial
investments.
▪ To take place in the first two years of activity.
▪ Literally, assets do not have to be located in Madeira. Nevertheless, we consider that they should.

18
Additional cap to tax benefits granted under the
new regime (2015-2027)
▪ 20,1% of the annual gross added value obtained in Madeira; or
▪ 30,1% of the annual incurred cost with labour in Madeira; or
▪ 15,1% of the annual turnover in Madeira.

19
General CIT rates
▪ The general CIT rate of 14,7% is applicable to:
− income derived from Portuguese source (except MFZ); or
− income above the referred limits of taxable income enjoying the reduced rate.
▪ A reduced rate of 11,9% is applicable to entities legally certified as small and medium
enterprises, up to € 25.000 of taxable income.

20
The critical issues
▪ International developments on tax harmonization.
▪ Substance and effective management requirements for licensed entities.
▪ Scope of activities of pure and other Holdings.
▪ Scope of activities of service companies (non-credit and non-financial).
▪ Special tax on undocumented / entertainment and motor / tax haven expenses.
▪ Special payment on account (PEC) of CIT.
▪ State / Regional surcharge.
▪ Transfer pricing regulations.
▪ Restriction on the deductibility of financing costs.
▪ Due diligence matters.

21
International developments on tax harmonization
▪ MFZ has been waived from the EU Code of Conduct analysis (which enables the enforcement of the Netherlands Double Tax
Treaty, for instance).
▪ MFZ has been waived from OECD harmful tax competition analysis.
▪ The MFZ regime has changed substantially starting from 1 January 2012, but not due to IMF/ECB/European Commission scrutiny.
▪ The European Commission, by decision of 8 May 2014, has authorized the extension of the regime III (2013-2020) for entries
taking place until 31 December 2014 (previously new entries into the regime were barred from 30 June 2014 onwards). This
extension has been transposed into Portuguese domestic law on 30 September and between 1 July 2014 and the latter date new
entries into the regime were nevertheless accepted by the entity managing the Free Zone and by Tax Authorities in Madeira.
▪ A new State Aid regime (2015-2027) – regime IV, applicable to entities registered after 1 January 2015 has been approved,
currently allowing entrants until 31 December 2023 benefits until 2027.
▪ Only regime IV is currently in force.

22
Substance and effective management requirements
for licensed entities
▪ E-business (internet service and content providers, e-commerce), telecommunications and holding of
participations and intellectual property are mobile activities that may be easily driven to the MFZ but
loosing tax revenue countries will probably try to challenge these migrations.
▪ The 2007-2027 EU State Aid regimes for MFZ companies: benefiting companies should not only create and
maintain jobs in Madeira (as per the above mentioned on job creation requirements) but also apply the
tax reductions only to the profits resulting from activities effectively and materially performed in Madeira
(the determination of some of these concepts is up for discussion).
▪ The branch and the trust as relatively unexplored alternatives to substance and effective management
requirements.

23
Scope of activities of Pure and Other Holdings
▪ A popular myth: holding companies not incorporated as Sociedades Gestoras de Participações Sociais
(SGPS) must be mixed (holding and operating) companies.
▪ The legal permission of own portfolio management for commercial companies vs. the prohibition of
exclusive holding activity by non-SGPS companies.
▪ The mixed, impure and atypical holding companies.
▪ Job creation and investment requirements are not literally applicable to companies whose main activity
consists in management of shareholdings of a non-financial nature (2015-2027 regime).

24
Scope of activities of service companies
(non-credit and non-financial)
▪ Credit Institutions and the receiving of deposits for their own account, towards the public.
▪ Credit Institutions and Financial Companies and the professional exercise of listed activities.
▪ Non-Public (bonds, commercial paper, shareholders loans, labour loans, payments in advance or
outstanding, treasury operations within group companies, vouchers or cards). The case of the specific and
isolated party to a contract outside the group. The legal permission of own portfolio management.
▪ Cash pooling and passive investment. The Sociedades de Simples Administração de Bens.

25
Special tax on undocumented / entertainment and motor /
tax haven expenses
▪ The special tax is a replacement of potential PIT / CIT avoided by the beneficiary of the expenses.
▪ The scope of the MFZ benefits under the new regime does not encompass all the situations below.
▪ The rates are as follows:
‒ Undocumented expenses – 50% in all cases;
‒ Payments to entities established in jurisdictions with more favorable tax regimes - 35% or 55%, depending on the activities carried out
by the payor and/or if it is partially or totally exempt;
▪ In the remaining situations, the specified rates are only applicable if the entities in question are liable to standard CIT rates - in case
of entities benefiting from the 5% reduced rate, the mentioned rates are applicable in proportion:
─ Costs with passenger and mixed passenger and cargo vehicles - 10% / 27,5% / 35%, depending on acquisition cost;
─ Entertainment expenses – 10%;
─ Per diem allowances and compensation for the use of private vehicle paid to workers and not invoiced to clients – 5%;
─ Redundancy payments made to directors and managers, unless related to the fulfillment of productivity goals set out in contract – 35%;
─ Bonuses paid to directors and managers – 35%;
─ Expenses or charges related to bonuses and other variable compensation paid to managers, administrators and managers - 35%;
─ Dividends distributed to tax exempt entities when the shares granting entitlement to the dividend are held for less than one year – 23%;
─ All previous rates are increased by 10% in the case of payments made by entities with a tax loss in the relevant year.

26
Special payment on account (PEC) of CIT
▪ Under the black letter of the law, entities established in the MFZ were liable to the PEC even when the tax exemption
regime was in force, although it was never charged to them.
▪ In 2004 a rule was enacted expressly exempting certain kinds of entities from the PEC, namely fully CIT exempt
entities such as the State, municipalities, etc. This rule did not include a reference to taxable entities with exempt
income, as was the case of entities established in the MFZ.
▪ Tax Authorities started assessing the PEC to MFZ entities under the exemption regime in that year.
▪ Several court decisions ruled against the assessment, based on the ability to pay principle (entities with only exempt
income had no duty to pay on account of undue tax).
▪ Starting from 2006, a new rule was enacted, providing for a PEC limited to € 1.250 (€ 1.000 since 2009) for entities
only deriving tax exempt income.

27
Special payment on account of CIT
▪ That rule was declared unconstitutional by a decision of the Constitutional Court in 2009, also based on the ability to
pay principle.
▪ In 2010 a new rule was enacted, providing for an exemption of PEC for entities with only exempt income.
▪ From then on, the limitation to € 1.000 was abolished and MFZ entities became liable to PEC according to the general
rules, provided that they:
─ had non-exempt income (such as Portuguese non-MFZ source income) and were under the previous exemption regime; or
─ were already under the rate reduction regimes.
▪ The MFZ exemption regime ended on 31 December 2011, which means that all MFZ entities under the 2013-2020
regime were liable to PEC according to the general rules, ranging between € 850 and € 70.000, levied at the rate of
1% on the previous year turnover liable and non-exempt.
▪ For the new 2015-2027 regime, all MFZ entities were only liable to PEC proportionally to the CIT rate applicable.
▪ However, since 2019, PEC became no longer mandatory for most companies, which could request an exemption as
long as they had their tax situation in good standing.
▪ Finally, the State Budget Law for 2022 has extinguished PEC for good. Hence, it is no longer due.

28
State / Regional surcharge
▪ The CIT Code currently establishes a State surcharge for companies incorporated in the mainland of 3% on
income from € 1.500.000 up to € 7.500.000, of 5% on income from € 7.500.000 up to € 35.000.000 and of
9% on income above € 35.000.000.
▪ This surcharge was enacted in 2010 (with different brackets and rates).
▪ However, the surcharge was “transposed” into Madeira legislation by a Regional Legislative Decree,
issued by the Parliament of the Autonomous Region of Madeira, under its powers to legislate in tax
matters.
▪ Such transposition was apparently devoid of any effects, as:
a) The surcharge established in the CIT Code is applicable to the entire Portuguese territory, regardless of such
“transposition”.
b) The Regional Legislative Decree created a regime which was an exact copy of the surcharge established in the
CIT Code.

29
▪ There is, however, one significant difference between both regimes.
▪ In 2011 a rule was enacted by the Parliament of the Autonomous Region of Madeira exempting entities established in
the MFZ from the surcharge, whether they were under the exemption or the reduced rate regimes (this rule was
enacted following an administrative order of the Regional Finance Secretary, issued in 2010 and providing for the
same surcharge exemption for MFZ entities. This administrative order was however of infra-legal status).
▪ This rule was not included in the CIT Code provisions establishing the CIT surcharge.
▪ However, it is a fact that the revenue raised by the CIT collected from entities established in Madeira, even in the MFZ,
belongs to the Regional Government.
▪ Could the Regional Parliament legislate to exempt MFZ entities from the surcharge? Is the exemption legal?
▪ In our view it is doubtful, as the creation of this exemption was not comprised in the list of legislative powers in tax
matters granted to the Regional Parliament by the Regional Finance Law; moreover, this Law expressly provides that
all matters relating to the MFZ regime must be dealt with by a law of the National Parliament (or of the National
Government, acting under an authorization to legislate granted by the Parliament).

30
▪ Regional legislation has been amended to clarify the issue in 2014 but doubts remained.
▪ However, in 2016, Tax Authorities have issued an Administrative Ruling clarifying this subject. Regarding the 2013-
2020 regime MFZ entities deriving taxable income under the reduced rates were excluded from the payment of
regional surcharge. However, this exclusion does not apply to MFZ entities under the new 2015-2027 regime, as they
benefit from an 80% reduction of the Regional surcharge applicable to the taxable income liable to the reduced rates;
on the other hand, taxable income liable to the standard CIT rates is fully liable to Regional surcharge.
▪ The problem has gained new light since the Parliament of the Autonomous Region of Madeira has established a
surcharge with different tax rates than the ones in the Mainland: 2,1% on income from € 1.500.000 up to €
7.500.000, of 3,5% on income from € 7.500.000 up to € 35.000.000 and of 6,3% on income above € 35.000.000.

31
Transfer pricing regulations
▪ Transfer pricing rules are specifically set in Article 63 of the Corporate Income Tax Code and on the
Ministerial Order (Portaria) no. 268/2011, of 26 November.
▪ The general rule is that taxpayers are deemed associated with a direct or indirect participation of 20%.
▪ Profitability of companies vs. MFZ reduced rates: makes it unlikely that transfer pricing rules are applied in
order to allocate higher income to MFZ companies.
▪ Companies whose total annual income in the previous year has not exceeded
€ 10.000.000 are waived from documentation compliance requirements.
▪ Although is not likely that the Portuguese Tax Authorities will focus their efforts and audits on CIT low-
taxed MFZ companies, the fact is that some have been inspected due to their high turnover.

32
Restriction on the deductibility of financing costs
▪ New rules were introduced by the Law approving the Reform of the CIT Code in this regard.
▪ Financing costs are now only deductible up to:
i. € 1.000.000 (previously € 3.000.000); or
ii. 30% of earnings before net financial costs, depreciation and taxes – EBITDA;
whichever is higher.
▪ Amounts exceeding these limits may be carried forward and deducted in the subsequent 5 years, provided that the
deduction relating to those years is below them. Amounts not used under the percentage of EBITDA limit (but not
under the € 1.000.000 limit) may also be carried forward for the same period and used to absorb excesses verified in
regard of it in subsequent years.
▪ The regime applies to permanent establishments of non-resident entities.
▪ The regime applies proportionally in the case of taxable periods shorter than one year (such as on the starting-up or
winding-down of business).
▪ Tax groups may opt to apply the regime on a consolidated basis for a minimum period of 3 years, subject to certain
restrictions, although the option does not increase any of the above limits (previously the option was not available
and the regime applied on an individual basis even to the members of a tax group).

33
Due diligence matters (I)
▪ Are you getting consulting services invoices from mainland Portugal at the 23% VAT rate?
– You shouldn’t. VAT should be self-assessed under the reverse charge mechanism and the correct rate is 22%. See
Articles 2 (1) (e) and (g), and (5), 6 (6) (a) and (16) of the VAT Code.
▪ Are you notifying the Bank of Portugal on foreign accounts held by MFZ companies / branches, of financial
operations with non-resident entities and of assets and liabilities vis-à-vis non-residents?
– You should. See Decree-Law no. 295/2003, of 21 November, Law no. 22/2008, of 13 May, Instructions 34/2009 and
27/2012 of the Bank of Portugal, EC Directive no. 88/361, of 24 July, and EC Regulation no. 184/2005, of 12 January.

34
Due diligence matters (II)
▪ Are you submitting monthly statistic reports to the Bank of Portugal?
– You should, as this report is mandatory to all entities established in Portugal under Instruction 27/2012 of the Bank
of Portugal. The report should be filed electronically by the 15th working day following the month to which it refers.
– Entities with less than € 100 000 of economic and financial operations per year with non-resident entities are
exempt from reporting.
▪ Are you notifying the Portuguese Tax Administration on the transfer for a consideration of shares in Sociedade
Anónima companies?
– In principle you should. See Articles 138 of the Personal Income Tax Code and 129 of the CIT Code.

35
Due diligence matters (III)
▪ Are you obtaining a certificate of tax residence or equivalent document from the royalty and service fee recipients?
– You should. See Article 33, paragraphs 14 and 15, of the Tax Incentives Statute.
▪ Are you appointing a contact person in Madeira?
– Although this requirement was established in an administrative order of the Regional Secretary for Planning and
Finance of Madeira, and therefore it does not have legal status, MFZ entities directly carrying out commercial,
industrial and services activities should appoint a staff member with professional domicile and personal residence in
Madeira as a contact person before the MFZ Office and the Sociedade de Desenvolvimento da Madeira, the entities
managing the Free Zone.

Portuguese blacklisted jurisdictions
36

37
Portuguese blacklisted jurisdictions
– the special case of Gibraltar
▪ Gibraltar is not a constituent part of the United Kingdom – it is a British overseas territory.
▪ However, it was part of the EU pursuant to article 355(3) and of Declaration 55 Annexed to the Treaty on the Functioning of
the EU (which reads as follows: “Declaration by the Kingdom of Spain and the United Kingdom of Great Britain and Northern
Ireland - The Treaties apply to Gibraltar as a European territory for whose external relations a Member State is responsible.
This shall not imply changes in the respective positions of the Member States concerned.”).
▪ Therefore, it was highly doubtful whether Gibraltar’s inclusion in the Portuguese blacklist was compliant with EU law (Cyprus
was stricken from the list in 2011 on the basis of its prior accession).
▪ The UK has been condemned in the EU Court of Justice in 2005 for failing to implement in Gibraltar Council Directive nr.
77/799/EEC, of 19 December 1977, concerning mutual assistance by the competent authorities of the Member States, in
regard of indirect taxes (Gibraltar had already implemented it for direct taxes).
▪ Portugal has entered into an agreement for exchange of information in tax matters with Gibraltar, which works
independently from the Directive and which entered into force on 24 April 2011.
▪ Thus, the absence of exchange of information was no longer a valid argument for Gibraltar's inclusion in the list.
▪ Regardless from the above, Gibraltar has since withdrawn from the EU alongside with the UK, on 31 January 2020, but the
agreement for exchange of information in tax matters with Portugal still applies.

• Dividend received exclusion (dividends received by Portuguese companies).
• Underlying tax credit (for non-excluded received dividends).
• Capital gain full and partial exclusions (capital gains made by Portuguese companies).
• 85% exemption for IP income and 20-year goodwill amortization.
• Excluded foreign PE income.
• MFZ reduced rate (taxable income received by MFZ companies).
• Capital gain exemption (capital gains made by shareholders of Portuguese companies).
• General dividend withholding tax exemption (dividends paid to foreign shareholders of
Portuguese companies).
• Specific withholding tax exemption under the new 2015-2027 regime to foreign
shareholders of MFZ companies.
• New VAT rules applicable to e-commerce.
• Taxation of holdings (summary).
Taxation of MFZ companies
38

39
Dividend Received Exclusion
REQUIREMENTS FOR THE 100% EXCLUSION ON DIVIDENDS RECEIVED BY PORTUGUESE COMPANIES FROM
PORTUGUESE SUBSIDIARIES:
▪ 10% shareholding (capital or voting rights) – direct or both direct and indirect (direct participation is always
required).
▪ 12-month uninterrupted holding period completed either before or after the dividend distribution.
▪ The receiving company must not be taxed under the Portuguese tax transparency regime.
▪ Dividends do not qualify for the exclusion if they are tax deductible at the level of the subsidiary.
▪ Dividends qualifying for the exclusion are not liable to withholding tax.

40
EU/EEA SUBSIDIARIES:
▪ 10% shareholding (capital or voting rights) – direct or both direct and indirect (direct participation is always
required).
▪ The subsidiary must be subject and not exempt from one of the taxes listed in the Parent-Subsidiary
Directive or from a tax comparable to the Portuguese CIT, in the latter case at a nominal rate of at least
60% of the CIT rate in force (i.e., 12,6%), in both cases with the exception of distributions by entities
developing activities not targeted by the Portuguese CFC regime.
▪ Dividends do not qualify for the exclusion if they are tax deductible at the level of the subsidiary.

41
NON-EU/EEA SUBSIDIARIES:
▪ 10% shareholding (capital or voting rights) – direct or both direct and indirect (direct participation is
always required).
▪ The subsidiary must be subject and not exempt from a tax comparable to the Portuguese CIT at a nominal
rate of at least 60% of the CIT rate in force (i.e., 12,6%), except for distributions by entities developing
activities not targeted by the Portuguese CFC regime.
▪ The subsidiary must not be established in a blacklisted jurisdiction.
▪ Dividends only qualify for the exclusion if (a) they are not tax deductible at the level of the subsidiary and
(b) (i) the subsidiary is not subjectively tax exempt or (ii) if the subsidiary is subjectively tax exempt, the
dividends are not distributed out of exempt income at lower levels of the chain of participations (this last
criterion is applicable to distributions by exempt subsidiaries developing activities not targeted by the
Portuguese CFC regime).

42
Underlying tax credit
FOREING SOURCED DIVIDENDS (BOTH FROM EU/EEA STATES AND THIRD STATES) NOT ELIGIBLE FOR THE
100% EXCLUSION QUALIFY FOR AN UNDERLYING TAX CREDIT PROVIDED THAT THERE IS:
▪ 10% direct or indirect (no direct participation required) shareholding (capital or voting rights).
▪ This option implies considering the proportion of income tax paid by directly and indirectly held foreign
subsidiaries at their States of residence corresponding to the dividends distributed to the Portuguese
parent as taxable income in the latter’s sphere.
▪ Income tax paid by subsidiaries established in blacklisted jurisdictions or by subsidiaries held through
them is not eligible for this credit.
▪ The credit corresponds to the lowest of: (i) the proportion of income tax paid by directly and indirectly
held foreign subsidiaries corresponding to the dividends distributed to the Portuguese parent or (ii) the
Portuguese CIT that would be payable on the distributed gross dividends, plus the income tax paid abroad
by the distributing subsidiaries, deducted of related expenses and of withholding tax levied at source and
credited in Portugal.
▪ This indirect tax credit is deducted only after the standard credit to avoid international double taxation.

43
Capital gain 100% exclusion
REQUIREMENTS FOR THE 100% EXCLUSION ON GAINS MADE BY PORTUGUESE COMPANIES ON THE SALE OF
SHARES AND OTHER EQUITY INSTRUMENTS RELATING TO SUCH SHARES:
▪ 10% shareholding (capital or voting rights) – direct or both direct and indirect (direct participation is
always required).
▪ 12-month uninterrupted holding period must be completed at the time of disposal (≠ from 100% dividend
exclusion regime).
▪ The selling company cannot be subject to the Portuguese tax transparency regime.
▪ The subsidiary must be subject and not exempt from one of the taxes listed in the Parent-Subsidiary
Directive or from a tax comparable to the Portuguese CIT, in the latter case at a nominal rate of at least
60% of the CIT rate in force (i.e., 12,6%), in both cases except for distributions by entities developing
activities not targeted by the Portuguese CFC regime.
▪ The exclusion does not apply to capital gains on the sale of shares in subsidiaries established in blacklisted
jurisdictions or whose assets are comprised, directly or indirectly, in more than 50% of rights in rem over
immovable property in the Portuguese territory, acquired after 1 January 2014 and not assigned to an
agricultural, industrial or commercial activity not consisting in the sale of immovable property.

44
Capital gain 50% exclusion
REQUIREMENTS FOR THE 50% EXCLUSION CAPITAL ON GAINS MADE BY PORTUGUESE COMPANIES:
▪ Reinvestment of the sale price on assets qualifying as fixed tangible assets, intangible assets or non-
consumable biological assets.
▪ Capital gains on shares do not qualify for reinvestment.

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85% Exemption for IP income
and goodwill amortization
▪ Applies to income resulting from the assignment or licensing of patents, designs or industrial models and
software copyrights protected by IP rights subject to registration.
▪ Requirements of the Patent Box regime:
– Only in case of rights registered after 1 January 2014.
– The assignee must effectively use the patent, design or industrial models or software copyrights in
the scope of a commercial, industrial or agricultural activity.
– If the assignee is a related company, the IP cannot be used to produce deductible expenses for the
taxpayer;
– The assignee cannot be resident in a blacklisted jurisdiction.

46
▪ The acquisition cost incurred with certain intangible assets with unlimited-life acquired after 1 January
2014 and goodwill deriving from business combinations are deductible at a 5% yearly rate over 20 years.
▪ IP income derived by MFZ companies is taxed under the reduced rate of 5%.
▪ Combining the reduced rate with the Patent Box regime results on IP income being taxed at an effective
rate of 0,75%.
▪ The Patent Box regime was modified to follow the OECD BEPS Action 5 output – the “modified nexus
approach”.
85% Exemption for IP income
and goodwill amortization

47
Exemption method for foreign PEs
Portuguese companies (including MFZ ones) may opt to apply the exemption method to income derived
through their foreign PEs, provided that:
– Their profits are liable and non-exempt from a tax listed in the Annex to the Parent-Subsidiary Directive or from a tax
comparable to the Portuguese CIT, in the latter case at a nominal rate of at least 60% of the CIT rate in force (i.e., 12,6%).
– They are not located in a blacklisted jurisdiction.
– The tax effectively paid is not lower than 50 % of the tax that would be due under the Portuguese CIT rules, except if the
sum of the following categories of income does not exceed 25% of the total income:
• Royalties or other income derived from intellectual property rights, image rights or rights of similar nature;
• Dividends and income derived from the disposal of shares of capital;
• Income derived from financial leasing;
• Income derived from transactions proper of the banking business even if not carried on by credit institutions, relating to insurance, business
or from other financial activities entered into with entities in special relations for the purposes of the Portuguese transfer pricing provision?
• Income from invoicing companies that earn commercial and services income derived from goods and services purchased from and sold to
related entities, for the purposes of the Portuguese transfer pricing provision and that add no or little economic value?
• Interest or other capital income.

48
Exemption method for foreign PEs
– The relevant PE concept is the one established in double tax treaties in force with the source state or, in the lack
thereof, in the Portuguese domestic law.
– Under this regime foreign PEs are treated as fully separate entities (which is debatable under the general
domestic rules and the Portuguese tax treaties in force).
– This option has to cover all PEs of the same jurisdiction and must be kept during a minimum period of 3 years.

49
Non-excluded income – MFZ 5% rate
▪ Non-excluded income is taxed at a 5% rate, provided that the above job creation and investment requirements are
met.
▪ Income not covered by the 5% rate is taxed at the CIT rate in force in the Autonomous Region of Madeira – currently
14,7% (as opposed to the 21% rate applicable, as in the Mainland).
▪ Under the new 2015-2027 regime, income derived from holdings whose main activity consists in the management of
shareholdings of a financial nature are outside the scope of the MFZ regime and taxed at the standard CIT rate of
14,7%.

CAPITAL GAINS DERIVED BY HOLDERS OF PORTUGUESE (INCLUDING MFZ) COMPANIES ARE EXEMPT:
▪ If they are non-residents without a permanent establishment in Portugal to which the gain is imputable.
EXCEPT
▪ If made on Portuguese resident companies owning immovable property in Portugal, when more than 50% of the
company’s assets consist of Portuguese real estate, or the disposed company is a holding with control of a Portuguese
subsidiary company in those conditions;
▪ The non-resident holders are resident in blacklisted jurisdictions (tax havens);
▪ If more than 25% of the capital of the non-resident holders is held, directly or indirectly, by Portuguese resident entities
unless when the following conditions are met:
General capital gain exemption I
50

✓ The selling entity must be tax resident in another EU Member-State, in an EEA State provided that administrative cooperation measures
equivalent to those existing in the EU are in place with that State (in general terms exchange of information not limited by bank secrecy
and assistance in the collection of taxes) or in a Third State which has entered into a double tax treaty with Portugal providing for
exchange of information;
✓ The selling entity must be subject and not exempt from one of the taxes listed in the Parent-Subsidiary Directive or from a tax
comparable to the Portuguese CIT, in the latter case at a nominal rate of at least 60% of the CIT rate in force (i.e., 12,6%);
✓ The selling entity holds directly, or directly and indirectly (direct participation is always required), a shareholding of at least 10% of the
capital or voting rights of the Portuguese company which is being disposed of;
✓ 12-month uninterrupted holding period completed before the disposal of the Portuguese company;
✓ The transaction should not be an artificial arrangement or a series of artificial arrangements which has been put in place for the main
purpose, or one of the main purposes, of obtaining a tax advantage.
➢ A word of caution: this exemption rule has been amended frequently since 1998 and complex transitory regimes apply. It is crucial
to know when the participation was acquired in order to determine the applicable regime!
General capital gain exemption II
51

CAPITAL GAINS DERIVED BY HOLDERS OF NON-PORTUGUESE COMPANIES ARE SUBJECT TO CIT IN PORTUGAL:
▪ If at any time during the previous 365 days, the value of the shares or rights resulted, directly or indirectly, in more than
50% of real estate or rights over real estate located in the Portuguese territory.
EXCEPT
▪ If the real estate is assigned to an activity of an agricultural, industrial or commercial nature that does not consist in the
purchase and sale of real estate.
Capital gains on the sale of non-Portuguese companies
52

53
General dividend WHT exemption
DIVIDENDS PAID BY PORTUGUESE (INCLUDING MFZ) COMPANIES TO FOREIGN CORPORATE SHAREHOLDERS
ARE EXEMPT FROM CIT WITHOLDINGS PROVIDED THAT THERE IS:
▪ 10% shareholding (capital or voting rights) – direct or both direct and indirect (direct participation is always required).
▪ 12-month uninterrupted holding period completed before the dividend distribution (if holding period is only
subsequently completed WHT applies but a refund may be requested upon completion).
▪ The distributing company is not taxed under the Portuguese tax transparency regime and is liable and not exempt
from CIT (MFZ entities fulfil this condition).
▪ The shareholder is resident in an EU Member-State, in an EEA State provided that administrative cooperation
measures equivalent to those existing in the EU are in place with that State (in general terms exchange of information
not limited by bank secrecy and assistance in the collection of taxes) or in a Third State which has entered into a
double tax treaty with Portugal providing for exchange of information.
▪ The shareholder must be subject and not exempt from one of the taxes listed in the Parent-Subsidiary Directive or
from a tax comparable to the Portuguese CIT, in the latter case at a nominal rate of at least 60% of the CIT rate in force
(i.e., 12,6%).
▪ Distributions to shareholders not fulfilling one of these two latter requirements but developing activities not targeted
by the Portuguese CFC regime do not qualify for the exemption, contrarily to what happens in the case of CIT
exclusions for dividends received and capital gains made by Portuguese companies.

54
Specific WHT exemption under the new regime
(2015-2027)
DIVIDENDS PAID BY MFZ COMPANIES TO FOREIGN SHAREHOLDERS ARE EXEMPT FROM CIT and PIT
WITHOLDINGS PROVIDED THAT:
▪ The dividends derive from the activities carried out in the institutional scope of the MFZ taxable at a 5%
rate; or
▪ The dividends derive from income not taxable at the 5% rate but obtained outside of the Portuguese
territory;
with the exception of income derived from transactions with blacklisted jurisdictions (doubtful if this
exception does not apply only to the second bullet above).
INTEREST AND OTHER FORMS OF COMPENSATION FOR LIQUIDITY SUPPLIES PAID BY MFZ COMPANIES TO
FOREIGN SHAREHOLDERS ARE EXEMPT FROM CIT and PIT WITHOLDINGS PROVIDED THAT:
▪ The shareholders are not residents in a blacklisted jurisdiction.

55
VAT rules applicable to e-commerce
▪ Until 31 December 2014 services provided by e-commerce companies were taxed at the location of the provider;
▪ On 1 January 2015, the rules relevant to e-commerce companies changed, and VAT became charged at the place of
destiny, i.e., where the buyer has its domicile and with the VAT rates applicable in that Member-State;
▪ This meant that a MFZ e-commerce company started having two choices: to register, for VAT purposes, in each country
to which provides services; or apply to the online VAT Mini One Stop Shop (MOSS);
▪ MOSS was a special regime which envisaged to simplify the fulfilment of the obligations derived from e-commerce
services (among others) within the EU. It basically allowed a company to deliver a single declaration and payment of
the VAT relating to all e-commerce services provided to consumers within the EU, on a quarterly basis; the Tax
Authority in question would then deliver to each Member-State the relevant information and VAT paid relating to the
acquisitions realized therein.
▪ On July of 2021, MOSS received a facelift and became OSS – “One Stop Shop”. The regime remained basically the
same, with the exception that it now includes a broader range of service providers eligible for the scheme and that the
threshold limit has been harmonised and reduced to € 10.000 (net of VAT) (in other words, a company may apply for
OSS scheme if it reaches said amount in sales or services to EU-wide customers within the year).

56
Taxation of Holdings (summary)
MFZ (Pure or Mixed)
HOLDING COMPANY
EU
COMPANY
OUTSIDE
EU
COMPANY
MFZ
COMPANY
PORTUGUESE
COMPANY
▪ 100% dividend exclusion on Portuguese, EU/EEA and Third State dividends
(if requirements are met).
▪ Underlying tax credit on EU/EEA and Third State dividends (if requirements
are met).
▪ 100% capital gain exclusion on Portuguese, EU/EEA and Third State shares
and associated equity instruments (if requirements are met).
▪ 50% capital gain exclusion on other assets (if reinvestment requirements are
met).
▪ Exemption method for foreign permanent establishments (if requirements
are met).

57
Taxation of Holdings (summary)
MFZ (Pure or Mixed)
HOLDING COMPANY
EU
COMPANY
OUTSIDE
EU
COMPANY
MFZ
COMPANY
PORTUGUESE
COMPANY
▪ 85% exemption for IP income (if requirements are met).
▪ 5% rate (2015-2027) on non-exempt income, derived from holdings whose
main activity consists in management of shareholdings of a non-financial
nature, not depending on the fulfillment of job creation and investment
requirements.
▪ 14,7% rate on other income.

58
General criteria for blacklisting jurisdictions
The State Budget Law for 2014 provided new general criteria for blacklisting jurisdictions. A jurisdiction
should be listed if:
▪ It does not have a tax on income comparable to the Portuguese CIT or if such tax has a nominal rate lower than
60% of the Portuguese rate (i.e., currently 12,6%).
▪ Its determination of taxable income diverges significantly from internationally accepted or applied standards,
namely by the OECD member countries.
▪ It has special taxation regimes or tax benefits, such as tax exemptions, deductions or credits, more favorable than
the Portuguese ones, that lead to a substantial reduction of taxation.
▪ Its law or administrative practice does not allow the access and exchange of information, namely tax, accounting,
corporate, banking or information of other nature that identifies the shareholders or other relevant people, the
holders of income, assets or rights and the performance of economic transactions.

59
General criteria for blacklisting jurisdictions
▪ Any listed jurisdiction may request to the Portuguese government a revision and removal from the blacklist grounded
on the non-fulfillment of the general criteria mentioned above.
▪ Any delisting will only have effects for the future and the list currently in force remains applicable until the publication
of a new one.
▪ The State Budget Law for 2017 implemented that are equally considered jurisdictions with more favorable tax regimes
– despite not being blacklisted in the Ministerial Order – all the ones that do not have a tax on income comparable to
the Portuguese CIT or if such tax has a nominal rate lower than 60% of the Portuguese rate (i.e., currently 12,6%)
provided that: a) the relevant Portuguese tax law mentions this assimilation; and b) individuals or entities with
residence in such a jurisdiction are deemed associated with Portuguese residents under the transfer pricing rules.
However, there is a carve-out for all EU Member-States and for EEA jurisdictions, provided that, in the latter,
administrative cooperation in the field of taxation measures equivalent to those existing in the EU are in place with
that State.

Madeira’s Practical Structures
▪ Commissionaire Structure
▪ Trading Structure
▪ Patent Royalty and Service Structure
▪ Dividend Reduction Structure
▪ Tax Sparing Structure (Loan)
▪ Controlled Foreign Company Blocking Structure
60

61
Commissionaire Structure
(Before)
SWISS
PRODUCER
SWEDISH
COMMISSIONAIRE
BELGIAN
RETAILER
SALE
COMISSION
COMISSION
▪ Corporate Income Tax:
‒ Taxation at the rate of 20,6% on the
commissions / trade income
received by the Swedish company.

62
Commissionaire Structure
(After)
‒ Taxation at the rate 5% on the
commissions / trade income
received by the MFZ company.
SWISS
PRODUCER
MFZ
COMMISSIONAIRE
BELGIAN
RETAILER
SALE
COMISSION
COMISSION

63
Trading Structure
(Before)
SALE
PORTUGUESE
PRODUCER
BELGIAN
RETAILER
‒ Taxation at the rate of 21% on the
trade income received by the
Portuguese company (incorporated
in the Mainland).

64
Trading Structure
(After)
PORTUGUESE
PRODUCER
MFZ COMPANY
BELGIAN
RETAILER
SALE
‒ Taxation at the rate 5% on the trade
income received by the MFZ
company.

65
Patent Royalty Structure
(Before)
JERSEY
COMPANY
SPANISH
COMPANY
▪ SPAIN
‒ 24% on royalty and service payments by the Spanish
company to the Jersey company;
‒ Deduction of royalty and service fees charged by the
Jersey company may be challenged at the level of the
Spanish company;
‒ 19% capital gain tax on the sale of the Spanish
company shares by the Jersey company.

66
Patent Royalty and Service Structure
(After)
JERSEY
COMPANY
MFZ COMPANY
SPANISH
COMPANY
▪ MFZ
‒ 0% withholding tax on licensing patent royalties and service payments
paid to the Jersey company;
‒ 0,75% effective CIT rate on patent royalties sublicensing income
received from Spanish company;
‒ 5% effective CIT rate on service income received from Spanish
company;
‒ Exemption (if conditions are met) or 5% capital gain tax on the sale of
the Spanish shares.
▪ SPAIN
‒ 0% withholding tax on royalty and service payments made by the
Spanish company to the MFZ company;
‒ Royalty and services fees charged by the MFZ company are deductible
at the level of the Spanish company.

67
Dividend Reduction Structure
(Before)
NON-EU
SHAREHOLDING
PORTUGUESE
MAINLAND
COMPANY
HOLDING DIVIDENDS
▪ Withholding at source on dividends distributed by Non-EU
shareholdings.
▪ Underlying tax credit in Mainland Portugal for withholding tax
levied at source on the Non-EU country, if the requirements of the
participation exemption are not met.
▪ Overall taxation of a maximum of 31,5%.

68
Dividend Reduction Structure
(After)
▪ Withholding at source on dividends distributed by the Non-EU
shareholdings.
▪ Exemption (if requirements are met) or 5% CIT (2015-2027
regime), with underlying tax credit for withholding tax levied at
source on the Non-EU country, in the MFZ.
▪ 100% dividend participation exemption on distributions by the MFZ
company to the Portuguese company, if requirements are met.
▪ Overall taxation = Only taxation of the distributing company if
exemption applies, or 5% of CIT with credit for withholding levied
at source on the Non-EU country.
NON-EU
SHAREHOLDING
PORTUGUESE
MAINLAND
COMPANY
MFZ HOLDING
COMPANY
HOLDING
HOLDING
DIVIDENDS
DIVIDENDS

69
Tax Sparing Structure
ITALIAN
COMPANY
MFZ COMPANY
OECD MODEL
TREATY
STATE COMPANY
ASSETS
LOAN
LEASE
INTEREST
PAYMENTS
▪ 0% withholding tax on rents on equipment paid by OECD
Model Treaty State company.
▪ 5% CIT on rents received by MFZ company.
▪ 0% withholding tax on interest paid by MFZ company under EU
Directive and domestic law.
▪ 15% tax credit regarding interest received by Italian Company.

70
Controlled Foreign Company Blocking Structure
(Before)
FRENCH
COMPANY
GIBRALTAR
COMPANY
JERSEY
COMPANY
▪ Profits of the Jersey and Gibraltar companies are
imputed even without distribution to the French
company and taxed at a 26,5% rate.

71
Controlled Foreign Company Blocking Structure
(After)
▪ Profits of the Jersey and Gibraltar companies are
not imputed / eventually imputed even without
distribution to the MFZ company;
▪ Despite the eventual imputation, CFC income is low
taxed at the level of the MFZ company [5% CIT];
▪ CFC income from Gibraltar and Jersey companies is
blocked at the level of MFZ, avoiding French CFC
rules and enabling a deferred taxation of that
income;
▪ Dividends paid by the MFZ company to the French
company may benefit from the Parent-Subsidiary
Directive.
FRENCH
COMPANY
GIBRALTAR
COMPANY
JERSEY
COMPANY
MFZ HOLDING
COMPANY

▪ In the preparation of this presentation, every effort has been made to offer current, correct and clearly expressed information. However, the said
information is intended to afford general guidelines only. This presentation reflects information current at 18 October 2022.
▪ This presentation is distributed with the understanding that RICARDO da PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. is
not responsible for the result of any actions taken on the basis of information herein included, nor for any errors or omissions contained herein.
▪ RICARDO da PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. is not attempting through this work to render legal or tax advice
and the information in this presentation should be used as a research tool only, and not in lieu of individual professional study with respect to client
legal matters.
▪ Portuguese domestic legislation, foreign legislation, EU Directives and tax treaties have anti-abuse provisions, and each client structure should be
analysed taking those into account.
▪ RICARDO da PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. is the copyright owner of this presentation and hereby grants
you a non-exclusive, non-transferable license to use this presentation provided that you do not modify its content in any way, that you keep its
proprietary notices of RICARDO da PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. and that you do not retain any copyright
or other proprietary notices displayed on such content.
General warning, disclaimer, copyright and authorised use
72

Recent Tax Recognition
▪ Chambers & Partners – Ricardo Band 1 / RPBA Band 3 (2022 / 2021) | Ricardo Band 2 / RPBA Band 3 (2020 / 2019 / 2018 / 2017 / 2016) | Ricardo Band 1 / RPBA Band 3 (2015 / 2014 / 2013) | Ricardo
highlighted in Band 1 in the Private Wealth Law practice area of the High Net Worth (HNW) guide (2020 / 2019 / 2018)
▪ Legal 500 – Ricardo, Ana Isabel and Rita are Recommended Lawyers / RPBA Band 2 (2022 / 2021 / 2020 / 2019 / 2018) | RPBA Band 3 (2017 / 2016 / 2015 / 2014 / 2013)
▪ Best Lawyers – Ricardo recognised as "Tax Law Lawyer of the Year” (2017) and ranked under the "Tax Law" practice area and the "Tax Planning" subspecialty (2022 / 2021 / 2020 / 2029 / 2018 / 2017 / 2016 /
2015 / 2014 / 2013 / 2012 / 2011) | Ana Isabel Correia recognised as "Tax Law Lawyer of the Year” (2020) and ranked under the "Tax Law" practice area (2022 / 2021 / 2020 /2019) / RPBA Tax Law Firm of the
Year in Portugal (2020)
▪ Who’s Who Legal – Ricardo ranked as a top lawyer in the Corporate Tax Lawyers directory (2021 / 2020 / 2019 / 2018 / 2017 / 2016 / 2013) / Ricardo recognised as a top lawyer in the Private Client practice
area (2020 / 2019 / 2018 / 2017)
▪ International Tax Review – Ana Rita Pereira included in the Women in Tax Leaders guide (2021 / 2020 / 2019 / 2018 / 2017)
▪ ITR World Tax – Ricardo, Ana Isabel Correia and Ana Rita included in the Tax Controversy Leaders guide (2022 / 2021 / 2020 / 2019 / 2018 / 2017) | RPBA Tier 2 (2021 / 2020 / 2019 / 2018) | RPBA Tier 3
(2017 / 2016 / 2015 / 2014) | RPBA Tier 4 (2013 / 2012 / 2011)
▪ ITR World Transfer Pricing – Ricardo mentioned / RPBA Tier 3 (2022 / 2021 / 2020 / 2019 / 2018 / 2017 / 2016 / 2015 / 2014)
▪ Leaders League – RPBA and Ricardo mentioned as “Excellent” under the "Corporate Tax" practice area (2022 / 2021)
▪ Corporate LiveWire – Ricardo da Palma Borges chosen as the winner of the Finance Award for Tax Lawyer of the Year – Portugal (2017) / Ricardo da Palma Borges chosen as the winner of the Finance Award for
Excellence in Tax Planning – Portugal (2016)
▪ Global Law Experts - RPBA Boutique Tax Law Firm of the Year in Portugal (2017 / 2015) / RPBA Tax Law Firm of the Year in Portugal (2016)
▪ Expert Guides – Ricardo ranked as a top lawyer in the Tax Lawyers directory (2022 / 2021 / 2020 / 2019 / 2018 / 2017 / 2016)
▪ Corporate Intl Magazine Global Award – RPBA Tax Law Firm of the Year – Portugal (2018 / 2017 / 2016 / 2014)
▪ Corporate Intl Magazine Legal Award – RPBA Boutique Tax Law Firm of the Year – Portugal (2015)
▪ Acquisition International Tax Award – RPBA Tax Law Boutique Firm of the Year – Portugal (2015)
▪ Acquisition International Legal Award – RPBA Boutique Law Firm of the Year – Portugal (2014)
▪ Tax Directors Handbook – Ricardo mentioned / RPBA Tier 3 (2015) and Tier 4 (2014)
73

(+351) 212 402 743
geral@rpba.pt
www.rpba.pt
www.linkedin.com/company/rpba
www.slideshare.net/rpba
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