1 Portugal Taxation FUNDS AND FUND MANAGEMENT Taxation of funds The investment funds tax regime is, mostly, governed by articles 22, 23, and 24 of the Tax Benefits Code (TBC), as well as by several other separate laws. Securities investment funds (fundos de investimento mobiliário, UCITS) Income, capital gains excluded, obtained in the Portuguese territory by securities investment funds incorporated and operating under Portuguese legislation is subject to withholding tax at source in the same conditions as those applicable to individual residents. If such income is not subject to withholding tax, it is subject to tax at a flat rate of 25 percent on the net year amount, which must be paid to the state by the fund management company until the end of April, following the year to which the income relates. Foreign income, capital gains excluded, is subject to tax at a flat rate of 25 percent on the net year amount (20 percent for income derived from bonds, other debt certificates, investment funds, and income from shares). The tax must be paid by the fund management company, by the end of April following the year to which the income relates. Capital gains, whether obtained in the Portuguese territory or abroad, are subject to tax at a flat rate of 10 percent on the positive difference between the capital gains and the capital losses of the year, in the same conditions as those applicable to resident individuals. The tax must be paid by the fund management company by the end of April, following the year to which the income relates. General rule, the criterion to be used in the sale of securities is the FIFO (first in first out). With respect to shares acquired before 1 January 2001, the applicable method is the LIFO (last in first out). Capital gains arising from shares held for more than 12 months and from debt securities are not subject to taxation.
2 2 Portugal Taxation Real estate/property investment funds (fundos de investimento imobiliário, FII) Rental income obtained by the real estate/property investment funds incorporated and operating under Portuguese legislation, except for low income property subject to the control costs legal regime, is taxed at a flat rate of 20 percent (net of maintenance and conservation expenses effectively supported, provided both are duly documented), and must be paid by the end of April of the following year by the fund management company. Any amount previously withheld in the sphere of the fund will be deemed as a payment on account and, consequently, as a tax credit. Real estate/property capital gains, except for those deriving from low income property subject to the control costs legal regime, are taxed at a flat rate of 25 percent, charged on 50 percent of the positive difference between the realized capital gains and the realized capital losses, determined according to the rules of the personal income tax code (código do imposto sobre o rendimento das pessoas singulares, PIT). This tax must also be paid by the end of April of the following year, by the fund management company. Any other income obtained by these funds will be subject to tax in the terms referred to in the previous section, regarding securities investment funds. Neither municipal property tax (imposto municipal sobre imóveis, IMI) is due on real estate/property owned by these types of funds, nor is municipal property transfer tax (imposto municipal sobre as transmissões onerosas de imóveis - IMT) levied on the acquisition of real estate/property by the fund. Notwithstanding, those exemptions are not applicable to immovable property of closed or mixed ended funds (privately issued), provided that the units are held by non-qualified investors. However, the IMI and the IMT tax rates are reduced in 50 percent. Funds of funds The income derived from the participation units held by funds in other funds incorporated according to the Portuguese legislation is exempt from corporate income tax (imposto sobre o rendimento das pessoas colectivas, CIT). Any other income obtained by these funds not comprised in the abovementioned rule will be subject to tax in the terms referred to for securities investment funds. Venture capital funds (fundos de capital de risco, FCR) Income obtained by venture capital funds incorporated and managed under the Portuguese legislation is exempt from CIT.
3 3 Portugal Taxation Moreover, corporate restructuring and internationalization funds (fundos de investimento de reestruturação e internacionalização empresarial, FRIE) are subject to the same tax regime as venture capital funds. Real Estate investment funds in forest resources (fundos de investimento imobiliário em recursos florestais, FIIRF) Income obtained by real estate investment funds incorporated and managed under the Portuguese legislation is exempt from CIT, provided that at least 75 percent of its assets are related to the exploration of forest resources and, provided that this exploration is submitted to approved and executed plans of forest management, in accordance with the regulation applied or forest certification carried through by the legally certified entity. Credit securitization funds (fundos de titularização de créditos, FTC) Income obtained by FTC is subject to the general CIT regime and, consequently, taxed at the general CIT rate of 12.5 percent to the amount of EUR 12,500 and 25 percent to the remaining exceeding amount (plus municipal surcharge of up to 1.5 percent on the taxable income). In the determination of the fund s taxable profit, the amounts due to the unitholders are considered tax deductible costs of the respective financial year. Real estate investment funds for housing rental (fundos de investimento imobiliário para arrendamento habitacional) Income obtained by FIIAH (incorporated and operating under the Portuguese legislation between 1 January 2009 and 31 December 2014) is exempt from CIT. It is also important to refer that the real estate buildings assigned to the portfolio of FIIAH benefit from IMI exemption, if destined to rental of permanent lodging. The acquisitions of real estate covered by the new regime are exempt from IMT and stamp duty, as long as certain requirements are met. This incentive will be in force until 31 December 2020, date in which the FIIAH will be converted into real estate investment funds and entirely subject to the respective tax regime (in spite of the possibility of the referred funds being winded-up at an earlier date).
4 4 Portugal Taxation Other funds Fundos de gestão de património imobiliário (FUNGEPI) are open-ended real estate/property investment funds. Accordingly, their tax regime is the one applicable to the real estate/property investment funds. Special investment funds (fundos especiais de investimento, FEI) are a type of undertaking for collective investments which allow a differentiated combination of the rules, techniques, and limits applicable to securities investment funds and which may invest in assets other than securities, financial derivatives, and liquidity. These types of funds are, in principle, subject to the same tax regime as the other securities investment funds. Fundos de reabilitação urbana (FRU) Income obtained by FRU incorporated in accordance with Portuguese law is exempt from CIT, to the extent that at least 75 percent of its real estate portfolio is located on an urban rehabilitation area. It is also important to mention that rehabilitated urban property is exempt from IMI during the first five years after the rehabilitation, renewable for the same period. 3.2 Taxation of resident unitholders/investors in a resident fund Main taxation characteristics applicable to income obtained by resident unitholders on securities investment funds, real estate/property investment funds and funds of funds Resident unitholders in a Portuguese fund are taxed differently on the proceeds from the funds, depending on whether they are individuals obtaining income outside the scope of a commercial, industrial or agricultural activity, entities subject to CIT or individuals that carry out a commercial, industrial, or agricultural activity. Proceeds include the distribution of profits and redemption gains. The corresponding taxation rules are in general as follows: Entities subject to CIT and individuals that carry out a commercial, industrial, or agricultural activity, although not subject to withholding tax on income received by the funds, must include all the proceeds in their annual tax return hence being taxed at the general rates. Any amount previously withheld in the sphere of the fund will be deemed as a payment on account and, consequently, as a tax credit.
5 5 Portugal Taxation Accordingly, entities subject to CIT will be taxed at the general tax rate of 12.5 percent to the amount of EUR 12,500 and 25 percent to the remaining exceeding amount plus a municipal surcharge of up to 1.5 percent on the taxable income. Individuals that carry out a commercial, industrial, or agricultural activity will be subject to the respective PIT progressive rates which may vary from 10.5 percent to 42 percent. Individual unitholders that do not carry out a commercial or agricultural activity are tax exempt. They may, however, opt to aggregate the proceeds (i.e. include them in their income tax computation) and any amount previously withheld in the sphere of the fund will be deemed as a payment on account and, consequently, as a tax credit. Unitholders are, in any event, only subject to tax on the income distributed by the fund or derived from the redemption of participation units and not on any amounts not distributed. Securities investment funds (fundos de investimento mobiliário, UCITS) and real estate/property investment funds (fundos de investimento imobiliário, FII) Investors receiving income derived from units in UCITS and FII, incorporated and operating under Portuguese legislation that opt to aggregate that income in their income tax computation, may deduct 50 percent of the profits or liquidation proceeds distributed to the funds under certain requirements. Capital gains obtained by resident individuals in a UCITS, as well as in a FII, are exempt from taxation. However, the mentioned income may be aggregated with the investor s income. Moreover, in what concerns capital gains obtained by resident individuals having a commercial, industrial, or agricultural activity or by corporate entities are deemed as profits and the tax withheld or due by the fund is deemed as a payment on account. Furthermore, the capital losses obtained by the unitholders are not considered when the buyer is domiciled in a jurisdiction with a more favorable tax regime or in a black listed jurisdiction foreseen in the Government Rule no. 150/2004, of 13 February. Funds of funds incorporated and operating under Portuguese legislation Income obtained by Portuguese resident unitholders of funds of funds, incorporated and operating under the Portuguese legislation, is not subject to withholding tax being only subject to tax on 40 percent of the net amount, at the general tax rates 10.5 percent to 42 percent if they are individuals carrying
6 6 Portugal Taxation out a commercial, industrial, or agricultural activity, or at the rate of 26.5 percent (12.5 percent to the amount of EUR 12,500 and 25 percent to the remaining exceeding amount plus municipal surcharge of up to 1.5 percent) if they are entities subject to CIT. However, please note that these cannot benefit from any tax credit. Income derived from units in funds of funds obtained by individuals not comprised in the above-mentioned situation or by entities subject to CIT that do not mainly carry out an activity of a commercial, industrial, or agricultural nature is exempt from taxation. Venture capital funds (fundos de capital de risco, FCR) and real estate investment funds in forest resources (fundos de investimento mobiliário em recursos florestais, FIIRF) The income derived from units in venture capital funds and in real estate investment funds in forest resources incorporated and operating under the Portuguese legislation are subject to withholding tax at a rate of 10 percent, and not subject to withholding tax if the unitholders entities are exempt regarding capital income. This withholding represents a final payment, whenever the unitholders are nonresident entities without permanent establishment in Portuguese territory or whenever the income is obtained by resident individuals, subject to PIT, that do not carry out a commercial, industrial or agricultural activity. However, these individuals may opt to aggregate the proceeds with their taxable income and the previously withheld amounts will be deemed as a tax credit. Capital gains from the sale of units in venture capital funds and in real estate investment funds in forest resources, whether obtained by non-resident entities who do not benefit from the exemption foreseen in article 27 of TBC1 whether obtained by resident individuals, subject to PIT, that do not carry out a commercial, industrial or agricultural activity and that do not opt to aggregate the proceeds with their taxable income, are subject to tax at a rate of 10 percent on the positive difference between the capital gains and the capital losses of the year. 1 The exemption from CIT regarding capital gains obtained by non-resident entities is not applicable whenever: (i) more than 25 percent of the non-resident entity s share capital is directly or indirectly held by Portuguese resident entities, (ii) the non-resident entity is resident in a tax haven, or (iii) the participation relates to a Portuguese real estate company (namely a company in which more than 50 percent of its assets consist of real estate property located in Portugal) or to a resident holding company which controls such real estate company.
7 7 Portugal Taxation Unitholders of venture capital funds and of real estate investment funds in forest resources, incorporated and operating under the Portuguese legislation, that opt to aggregate the income obtained are only subject to tax on 50 percent of the profits distributed to the funds, at the general tax rates 10.5 percent to 42 percent if individuals or 26.5 percent (12.5 percent to the amount of EUR 12,500 and 25 percent to the remaining exceeding amount plus municipal surcharge of up to 1.5 percent on taxable income) if entities subject to CIT. Real estate investment funds for housing rental (fundos de investimento imobiliário para arrendamento habitacional, FIIAH) Income received by investors of FIIAH is exempt from (Imposto sobre o rendimento das pessoas singulares, PIT) and CIT, with the exception of income obtained by non-resident entities in territories subject to a privileged tax regime, cases in which a 20 percent withholding tax rate applies. 3.3 Taxation of resident unitholders/investors in a non-resident fund Income received by resident unitholders from investment in non-resident funds is treated as financial income. Accordingly, individuals and entities subject to CIT must aggregate the profits distributed by the non-resident fund with their taxable income, thus being subject to rates of up to 42 percent (individuals) and 26.5 percent, which includes the municipal surcharge of up to 1.5 percent on taxable income (entities subject to CIT). If there is a paying agent in Portugal, either mandated by the non-resident fund, or by the investor, financial income is withheld by the paying agent at 20 percent if the investor is an individual. Moreover, if the investor is a corporate entity or an investment fund, no withholding tax is levied. Resident individuals may opt to aggregate the proceeds with their taxable income and previously withheld amounts will be deemed as a tax credit. On an eventual sale of the units, the individual will be subject to a capital gain on the positive difference between the sale proceeds and the cost of acquisition, which will be subject to a 10 percent flat rate. 3.4 Taxation of non-resident unitholders/investors in a resident fund Non-resident unitholders are exempt from CIT and PIT on any income derived from participation units, including capital gains except if: the unitholders are entities held in more than 25 percent by Portuguese resident entities;
8 8 Portugal Taxation the unitholders are resident in a territory with a privileged tax regime; or the participation relates to a Portuguese resident real estate company (namely a company in which more than 50 percent of its assets consist of real estate located in Portugal) or to a resident holding company which controls such a real estate company), on the redemption of those units or profits distributed by the fund. Income received by investors of FIIAH is exempt from PIT and CIT, with the exception of income obtained by entities resident in territories subject to a privileged tax regime. 3.5 Taxation of fund management/custodian companies Fund management companies are subject to the tax rules applicable to all Portuguese resident companies, without any special tax incentives. The tax rate is of 12.5 percent to the amount of EUR 12,500 and 25 percent to the remaining exceeding amount increased by a municipal surcharge, of up to 1.5 percent on the taxable income, giving a total tax liability of 26.5 percent (fund management companies that were established in the Madeira Free Trade Zone until 31 December 2000 enjoy a zero tax rate until the year 2011 for further details, please refer to 3.8 below). Normally, the services rendered by fund management companies are regarded as exempt for VAT purposes and, in principle, subject to stamp duty. This results from the fact that fund management companies are deemed to be financial institutions, which means that their input is not deductible for VAT purposes. These companies are jointly and severally liable for the taxes due in the sphere of the investment funds they manage. Regarding the fees charged by the fund management companies, there is a distinction between the management fee, the subscription commission and the redemption commission. Additionally, a custody commission is charged by the depository. All these commissions are exempt from VAT and understandings issued by the tax authorities have also considered that they are exempt from stamp duty. 3.6 Entitlement to income Income arises to the investor only when it is distributed by the fund or in the case of a sale or redemption of the units.
9 9 Portugal Taxation 3.7 Double taxation agreements Portuguese and foreign funds may benefit from double taxation agreements (DTA) entered into between the foreign country and Portugal. In relation to foreign funds, this generally depends on a communication to the Portuguese tax authorities, including a form signed by the tax authorities of the country of origin of the beneficiary stating that the fund qualifies for the treaty purposes. Presently, Portugal has entered into 53 double taxation agreements, namely, with Argelia, Austria, Belgium, Brazil, Bulgaria, Canada, Cape Verde, Chile, Cuba, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Guinea-Bissau (pending official publication to enter into force), Hungary, Iceland, India, Indonesia, Ireland, Italy, Israel, Latvia, Lithuania, Luxembourg, Macao, Malta, Mexico, Morocco, Mozambique, Netherlands, Norway, Pakistan, People s Republic of China, Poland, Republic of South Korea, Republic of Singapore, Romania, Russia, Slovakia, Slovenia, South Africa,, Sweden, Switzerland, Spain, Tunisia, Turkey, the United States, United Kingdom, Ukraine, and Venezuela. 3.8 Other tax-favored vehicles Fund management companies established in the Madeira Free Trade Zone A fund management company licensed to operate within the Madeira Free Trade Zone, where the license was issued for the first time prior to 31 December 2000, is entitled to an exemption from CIT up to the year 2011, provided the participation units of the funds managed are fully subscribed by non-residents, except for their permanent establishments located therein, or by companies established in the Madeira Free Trade Zone, and provided fund s investments are made in securities issued by non-residents or other assets located outside the Portuguese territory. Notwithstanding, a maximum of 10 percent of the net amount of the fund may be represented by money, bank deposits, and inter-banking applications. Stock investment saving funds (fundos de poupança em acções, FPA) Income obtained from stock investment saving funds incorporated and operating under Portuguese legislation is exempt from CIT. These incomes are also exempt from PIT, except when it concerns to the positive difference between the owed amount at the closing of the stock investment savings and the amount delivered by the subscriber, regarding the mentioned in no. 3 of the article 5 of the CPIT.
10 10 Portugal Taxation Pension Funds (Fundos de pensões, FP) Income obtained from pension funds incorporated and operating under the Portuguese legislation is exempt from CIT and IMT. Moreover, we highlight the fact that individuals can deduct the tax assessed at a rate of 20 percent on the invested amount, if the referred amount has been taxed as a PIT income and if it s not associated to business and professional income. Retirement savings funds (fundos de poupança reforma, PFR) Income obtained from retirement saving funds, retirement/education funds, and education saving funds incorporated and operating under the Portuguese legislation is exempt from CIT. Individuals may deduct to tax assessed 20 percent of the invested amount in PFR up to the limit of EUR 400 (taxpayers under 35 years old), EUR 350 (between 35 and 50 years old) and EUR 300 (over 50 years old). However, in case this investment occurs after retirement, these amounts could not be deducted. Additionally, please note that income paid by the fund may be deemed either as pension income, or as investment income and, therefore, taxation (including withholding tax) occurs in accordance therewith. Holding companies (sociedades gestoras de participações sociais, SGPS), venture capital companies (sociedades de capital de risco, SCR), and venture capital investors (investidores de capital de risco, ICR) The capital gains and capital losses resulting from shares held, for more than one year, by SGPS, SCR, and ICR are not accounted for their taxable income, neither is the financial expenses incurred with its acquisition. However, the rule for gains is not applicable if the shareholdings were acquired from related entities, entities domiciled in a black listed jurisdiction foreseen in the Government Rule no. 150/2004, of 13 February, or from Portuguese entities that benefit from a special regime of taxation and were held for less than three years. Should any of the above-mentioned situations occur, the SGPS, the SCR, and the ICR must aggregate capital gains obtained from the sale of shares with their taxable income, thus being subject to a tax rate of 12.5 percent to the amount of EUR 12,500 and 25 percent to the remaining exceeding amount increased to 26.5 percent if a municipal surcharge of 1.5 percent on taxable income thereon applies.
11 11 Portugal Taxation However, if the sales proceeds are reinvested in another Portuguese company or in Portuguese debt certificates, those capital gains may only be taxable as to 50 percent of the amount, provided certain requisites are met. The reinvestment has to take place in the year of the sale, the preceding year or in the two subsequent years. This rule is proportionally applied should the proceeds not be fully reinvested. SCR and ICR may deduct, as a tax credit, an amount equal and up to the tax assessment of the previous five years, whenever that amount had been invested in companies with growth and valorization potential. Please note that it is expected the implementation of this regulation for societies placed in the EU, as well. 3.9 Transfer taxes, stamp duty, and capital duty Stamp duty is levied on the commissions charged by brokers, dealers, and financial intermediaries on the purchase or transfer of securities at a flat rate of 4 percent. Capital duties are not levied on the flotation of a fund s participation units. KPMG in Portugal Luís Magalhães KPMG & Associados - Sociedade de Revisores Oficiais de Contas, S.A. Edifício Monumental Av. Praia da Vitória, 71 - A, 11º Lisbon Portugal Tel Fax The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation.
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