Real estate, as an immovable factor, tends to be overtaxed in most countries and Portugal is no exception. Tax structuring and optimizing is crucial to minimize total acquisition costs and maximize investment returns. RPBA’s updated presentation deals with this challenging topic incorporating the latest developments, including tax incentives on rehabilitation, the OECD Multilateral Instrument rules on “real estate rich” companies and also the brand new SIGI company (the Portuguese equivalent of the REIT – Real Estate Investment Trust).

1. Real Estate Tax Planning
in Portugal
Ricardo da Palma Borges
ricardo@rpba.pt
www.rpba.pt
The basics

2. Portuguese relevant taxes after the
estate tax reform of 2003
2
Property Transfer Tax (PTT)
 Previously Imposto Municipal de Sisa;
 Currently Imposto Municipal sobre as Transmissões
Onerosas de Imóveis;
Property Ownership Tax (POT)
 Previously Contribuição Autárquica;
 Currently Imposto Municipal sobre Imóveis;
Gift and Inheritance Tax (GIT)
 Previously Imposto sobre as Sucessões e Doações;
 Currently Stamp Tax (individuals) or Corporate
Income Tax (corporate entities);
Stamp Tax (ST)  Imposto do Selo;
Capital Gains Tax (CGT)
 Part of Personal Income Tax (PIT) or Corporate
Income Tax (CIT).

3. Relevant entities
Joint Stock Company / Corporation or Portuguese
Sociedade Anónima (S.A.).
Private Limited Company or Portuguese
Sociedade por Quotas (Lda.).
Real Estate Investment Fund or Portuguese Fundo
de Investimento Imobiliário (FII).
Real Estate Investment Company or Portuguese
Sociedade de Investimento e Gestão Imobiliária
(SIGI).
3

4.  A favorable PIT regime for non-habitual tax residents (NHR) has been
introduced in 2008, under which those acquiring a Portuguese tax residence
without having one in the previous 5 years are granted, for a 10-year period:
• The exemption method to avoid double taxation regarding foreign source
income;
• An autonomous (rather than progressive) taxation of dependent and
independent work income from high value-added activities of a scientific,
artistic or technical nature (as defined by a Ministerial Order).
4
Interesting features of the Portuguese tax
system – Non-habitual resident (NHR)
regime

5.  Under the regime, foreign income is exempt, provided that it is taxed abroad (in the case of
dependent work income) or that it may be taxed abroad under a double tax treaty entered
into by Portugal or according to the OECD Model Tax Convention and taking into account the
reservations to the Model and the observations to its Commentary submitted by Portugal, in
the cases where no double tax treaty exists and provided that the Source State is not a
blacklisted jurisdiction for Portuguese tax purposes (for all other categories of income, except
(i) independent work income, which must additionally derive from the mentioned high value-
added activities in order to qualify for the exemption, and (ii) pensions, where in the absence
of Portuguese contributions, the foreign source payment of the income may be enough to
qualify for the exemption).
 Dependent and independent work income from high value-added activities is taxed at a 20%
autonomous rate (regardless of its domestic or foreign source, which means that the rate may
apply to foreign income not qualifying for the above-mentioned exemptions).
Interesting features of the Portuguese tax
system – Non-habitual resident (NHR)
regime (cont.)
5

6. For more information on this regime please read our presentation:
https://bit.ly/2IgYrMX
You can also visit our microsite www.nonhabitualtaxresident.com or scan the below
QR code with your smartphone:
Should you require in-depth information on this subject please check our Information
Note available at https://bit.ly/2UbXqqE
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Interesting features of the Portuguese tax
system – Non-habitual resident (NHR)
regime (cont.)

7.  Exclusion from taxation of shares or quotas in Joint Stock Companies / Private Limited Companies
acquired previously to January 1st 1989 (regardless of the holding of real estate by the company)
 Portuguese companies or also foreign equivalent companies?
 Ubi lex non distinguit nec nos distinguere debemos:
• Silence of the law;
• EU and tax treaty principle of non-discrimination.
 Tax treaties entered into by Portugal generally follow the OECD Model Tax Convention, whose
article 13, paragraph 5, attributes an exclusive taxation right on capital gains in shareholdings to the
State of residence of the alienator, preventing the State of source from levying its own taxes.
 Therefore, some foreign wealthy individuals have moved to Portugal and acquired residency herein
before disposing of their investment empires acquired prior to 1989 tax-free.
 PIT capital gains on the sale of a taxpayer's personal and permanent residence are not taxable,
insofar as the sale proceeds are reinvested in another personal residence in the Portuguese,
European Union or European Economic Area territory. Alternatively, those sale proceeds may be
reinvested in contributions to the public capitalization regime or in an insurance policy / open
pension fund that generates periodic payments, insofar as the taxpayer or the spouse is at least age
65 or retired.
Interesting features of the Portuguese tax
system – Capital gains
7

8. Interesting features of the Portuguese tax
system - GIT
8
 From January 1st 2004 “Close Family” (spouses, civil law partners – since 2009 -, children,
grandchildren, parents and grandparents) is exempt from GIT.
 Non-exempt situations of disposal of most Portuguese assets with individuals as beneficiaries are
taxed through a 10% ST [with the notable exceptions of (i) shares in companies whose head-office,
effective management or permanent establishment is in the Portuguese territory, and (ii) credit and
other patrimonial rights over individuals or companies resident, with head-office, effective
management or a permanent establishment herein, in both cases, (i) and (ii), when the individual
beneficiaries are non-Portuguese residents; these two situations are not liable to GIT].
 Situations involving disposal of non-Portuguese assets with individuals as beneficiaries are not liable
to GIT.
 Donations to corporate entities are income for CIT purposes.

9. Interesting features of the Portuguese tax system -
Tax Incentives for Urban Rehabilitation
 PIT benefits for Portuguese tax residents:
a. The owner of the real estate is able to deduct 30% of the expenses incurred – up to 500€ – in order to rehabilitate
the property. Such costs must be proven and depend from prior certification. Consider i. or ii. below.
b. Rental income derived from rehabilitated real estate is taxed via an autonomous rate of 5%. Consider i. or ii. below.
c. Capital gains fully derived from the disposal of rehabilitated real estate are taxed via an autonomous rate of 5%.
Consider i. below.
 VAT benefits:
d. Works of urban rehabilitation, defined under the specific Legal Regime, benefit from a reduced VAT rate of 6%,
instead of the general rate of 23%.
 Further requirements and notes:
i. The real estate must be located in “urban rehabilitation areas” – special regions designated under the Legal
Regime of Urban Rehabilitation.
ii. The real estate must be rented and subject to the phased update of rent according to the NRAU regime. The
benefits are granted on the condition that (a) either the rehabilitation work increases the preservation state of the
real estate at least two levels above the pre-rehabilitation state, (b) or that it achieves the minimum level of
preservation state “good”, as long as the construction work done in the previous two years amounts to 25% of the
real estate tax value (Valor Patrimonial Tributário or VPT) and it is meant to be leased as a permanent residence.
These “works of urban rehabilitation”, defined under the Legal Regime of Urban Rehabilitation, must be verified by
the local municipality before and after the rehabilitation.
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10. Interesting features of the Portuguese tax system –
Tax Incentives for Urban Rehabilitation (cont.)
 PTT benefits:
a. Rehabilitated real estate is exempt from PTT in the first transaction after the rehabilitation, if the property
is meant exclusively to be leased as a permanent residence. Also if the property is meant for permanent
residence when the real estate is located in “urban rehabilitation areas”. Consider i., ii., and iv. below.
a. Purchases of urban property meant to be rehabilitated are exempt from PTT, as long as such works of
rehabilitation commence within 3 years from the date of acquisition. Consider i., ii., and iv. below.
 POT benefits:
Rehabilitated urban property is exempt from POT for a 3-year period, renewable for an additional period of 5
years. Consider i., ii., iii., and iv. below.
 Further requirements and notes:
i. The real estate must be located in “urban rehabilitation areas” – special regions designated under the Legal
Regime of Urban Rehabilitation –, or must have been built more than 30 years ago.
ii. The benefits are granted on the conditions that the rehabilitation work, under the Legal Regime of Urban
Rehabilitation, increases the preservation state of the real estate at least two levels above the pre-
rehabilitation state, that it achieves the minimum level of preservation state “good”, and that it complies
with requirements of energy efficiency end thermal quality;
iii. The renewal of the POT exemption is dependent on a deliberation by the Municipal Assembly.
iv. The exemption is granted after the completion of the rehabilitation work.
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11. Real Estate Investment Fund (FII) –
Legal regime, taxation and benefits
 Assets of investment fund: (i) urban real estate property or similar rights; (ii) rural or mixed real
estate and exploitation rights on immovable property; (iii) real estate companies (with conditions);
(iv) participating units in other FIIs (with conditions); and (v) derivatives which aim to hedge the
underlying risks of the FII assets.
 Assets with liens that excessively complicate their disposal cannot integrate the property of the FII,
namely assets given as colateral.
 Closed-end funds:
• (i) real estate and like-assets cannot be lower than 2/3 of total assets;
• (ii) construction projects cannot be more than 50% of total assets (60% for reconstruction);
• (iii) any immovable cannot represent more than 25% of total assets;
• (iv) the value of leased properties cannot be more than 25% of total assets;
• (v) indebtedness cannot be more than 33% of total assets;
• (vi) participation in real estate companies cannot exceed more than 25% of total assets.
 Advantageous CIT regime, in which capital gains, rental income and capital income are not
accounted for the determination of the taxable income, apart from the case in which this income
relates to an blacklisted offshore company; 21% CIT rate on taxable income; no withholding taxes on
the income received by the FII; No POT and PTT exemption (PTT exemption ceased in 2019).
 No Municipal or State Surcharge.
 ST is due on the net global value of the FII at a 0,0125% rate, on a quarterly basis.
 At the investor level, low taxation for non-Portuguese tax residents without permanent
establishment:
• 10% rate on income distributions and capital gains (arguably, provisions of double tax treaties may prevent
even this low taxation); 35% rate for investors in blacklisted offshore territory; 25% rate if the foreign
investor is indirectly controlled by a resident and there is no information exchange between tax authorities.
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12. Real Estate Investment Company (SIGI) –
Legal regime, taxation and benefits
 Joint stock company with a minimum share capital of € 5.000.000.
 SIGIs main activities are restricted to:
• acquisition of property rights, surface rights and other similar rights over properties, shops or
offices, for rental purposes or other similar economic activity. This includes acquiring rural
properties that can be used as a full-functional agricultural or forestry undertaking, rural
properties that are transformed into urban properties within three years after acquisition, as
well as carrying out construction and urban renovation projects;
• acquisition of shares in other SIGIs located in Portugal or in the EU or EEE, or units in FII,
complying with certain criteria.
 Requirements that must be respected:
• (i) after the 2nd year, real estate and like-assets (free of liens) cannot be lower than 80% of total
assets;
• (ii) after the 2nd year, rented properties must represent at least 75% of total assets;
• (iii) assets must be kept for a minimum period of 3 years;
• (iv) upon sale, at least 75% of the net proceeds must be reinvested;
• (v) indebtedness cannot be more than 60% of total assets.
 SIGIs must distribute the following income as dividends: 90% of the profits resulting from the
payment of dividends deriving from holdings or other investment vehicles; and 75% of the
remaining profits.
 Same advantageous tax regime as FII applies.
12

13. Other legal entities – Taxation and
benefits
 Real Estate Inventory or Compra de Imóveis para Revenda (CIR) tax status is available for individuals,
Portuguese companies or branches of foreign companies which, in principle, are:
• inscribed as such in the tax office;
• declare the “purchase for resale” in the public deed of acquisition;
• have the “purchase for resale” as an entrepreneurial activity (set in the social object in case of a company);
• register the real estate as inventory (not as a fixed asset) in their accounts.
 CIR defers / exempts the real estate from POT during 3 years in case of purchase for resale.
• possibility of cumulating a POT deferral / exemption during 4 years for plot construction if enterprise has
such an activity (set in the social object in case of a company) and a subsequent POT deferral / exemption
of 3 years on the sale of the built real estate.
 CIR provides a PTT upfront exemption on the purchase (if a previous “purchase for resale” has been made
in the previous year), or a refund of PTT paid upon resale (otherwise).
 Tax rates: 21% on lease, resale or development in the case of a company or branch, plus up to 1,5% of
Municipal Surcharge (total 22,5%) and 3%, 5% or 9% of State Surcharge (on taxable income in excess of €
1.500.000, € 7.500.000 and € 35.000.000, respectively); 0%-48% (the higher bracket being applicable to
income above € 80.640) in the case of a resident individual (plus an additional solidarity rate of 2,5% on
income in excess of € 80.000 and of 5% on income in excess of € 250.000).
 Low management and maintenance costs; high flexibility. 13

14. Direct or indirect purchasing of real estate
(PPT, POT, ST)
 PPT up to 6% (for housing purposes) or up to 6,5% (non housing purposes), as in an acquisition by a
company, and ST of 0,8% on the price or taxable value (whichever higher);
 POT of 0,8% for rural real estate and between 0,3%-0,45% for urban real estate (exemption during 3
years for permanent housing if the taxable value does not exceed € 125.000 for households with a
IRS taxable income not higher than € 153.300; on purchase for resale by companies / entrepreneurs
during 3 years);
 Numerous punitive measures on acquisition and holding of Portuguese real estate by a blacklisted
offshore company – namely, PPT rate of 10% and POT rate of 7,5%;
 ST on 5 or more year term financing of 0,6%, but exemption applies to interest paid on permanent
housing loans;
 The State Budget Law for 2017 enacted, in substitution of the 1% “Luxury” ST on housing real estate
with a taxable value above € 1 million, an Additional to the POT;
14

15. Direct or indirect purchasing of
real estate (Additional to the POT)
 This new Additional to the POT applies to owners, usufructuaries or superficiaries, of urban
property for housing purposes or building land located in Portugal, on January 1st of the relevant
year;
 Single owners with residential real estate or land for construction in Portugal above € 600.000 of
taxable value ("Valor Patrimonial Tributário" or VPT) are liable to Additional to the POT at a 0,7%
rate on the surplus of the € 600.000. If the sum of the taxable values exceeds € 1.000.000, the
surplus is subject to a marginal rate of 1%. If the sum of the taxable values exceeds € 2.000.000, the
surplus is subject to a marginal rate of 1,5%;
 Single owners which are married or in a civil partnership and choose the joint taxation regime – for
purposes of the Additional to the POT – are only liable to Additional to the POT if the sum of the
taxable value of their real estate is above € 1.200,000. The Additional to the POT applies a 0,7% rate
on the surplus of the € 1.200,000. If the sum of the taxable values exceeds € 2.000,000 the surplus
is subject to a marginal rate of 1%. If the sum of the taxable values exceeds € 4.000,000 the surplus
is subject to a marginal rate of 1,5%;
 If the taxpayers obtain income attributable to immovable property subject to the Additional to the
POT, the latter may be deducted from the IRS due in respect of rental income (Schedule F) or
business income obtained from rental or hosting activities (Schedule B);
15

16. Direct or indirect purchasing of
real estate (Additional to the POT) (cont.)
 If a company holds real estate, the Additional to the POT rate will be applied on the full taxable value of the real estate
at a rate of 0,4% – not only on the surplus of a threshold; Lessors cannot charge the Additional to the POT to lessees if
the sum of the taxable values does not exceed € 600.000;
 If the owner is a company and the real estate is simply used by its shareholder/director or any member of the
corporate bodies of such company (including their respective spouses, ascendants or descendants), the tax rate will be
of 0,7% on its full taxable value. If the sum of their taxable values exceeds € 1.000.000 the surplus is subject to a
marginal rate of 1%. If the sum of the taxable values exceeds € 2.000.000, the surplus is subject to a marginal rate of
1,5%. In our opinion, if the real estate is leased by the company to the shareholder or director the tax rate will be of
0,4%;
 Taxpayers may choose for CIT purposes: (i) to deduct the Additional to the POT as an expense; or (ii) to deduct the
Additional to the POT from the tax due, limited to the fraction corresponding to the income generated by that real
estate, in the context of rental or hosting activities, and up to that tax due.
 Numerous punitive measures on acquisition and holding of Portuguese real estate by a blacklisted offshore company –
namely, Additional to the POT rate of 7,5% on the sum of the taxable values of the real estate, without possibility of
deducting the charge for CIT purposes.
16

17. Direct sale of real estate (CGT)
 CIT CGT: at a 21% rate (which may be reduced to 10,5% in case of qualifying
reinvestment), plus Municipal surcharge up to 1,5%, and State surcharge of 3%, 5% or
9% (on taxable income in excess of € 1.500.000, € 7.500.000 and € 35.000.000,
respectively), if a Portuguese company or a permanent establishment in Portugal holds
the real estate; or at a 25% rate if a non-Portuguese company without a permanent
establishment herein holds the real estate;
 PIT CGT: 0%-48% (the higher bracket being applicable to income above € 80.640) in the
case of a resident individual, but only 50% of the capital gain is subject to tax (plus an
additional solidarity rate of 2,5% on income in excess of € 80.000 and of 5% on income
in excess of € 250.000); or at a 28% rate if a non-Portuguese resident individual holds
the real estate; or at a 35% rate if the real estate is held by an entity in a blacklisted
offshore territory. 17

18. Gift of real estate (ST / CIT)
 The free transfer by gift of Portuguese real estate:
• to an individual is liable to ST [at a 10% rate; close family (spouses, children,
grandchildren, parents and grandparents), is exempt from this 10% rate] - plus a ST
of 0,8%;
• to (i) a Portuguese or (ii) non-Portuguese tax resident company or (iii) to a
permanent establishment in Portugal, is liable to CIT [at a 21% rate, plus Municipal
and State surcharges in the cases (i) and (iii), and at a 25% rate in case (ii)].
 Gift will give rise to a new date of acquisition. The acquisition value for future
CGT purposes will be:
• under the PIT Code, the tax value for ST purposes (i.e. Valor Patrimonial Tributário
or VPT);
• under the CIT Code, the fair market value.
18

19. Indirect sale of real estate – sale of the company
(CGT / PT)
 If share/quotaholders (individual Portuguese or foreign residents, or corporate foreign
residents) sell the interest in the Portuguese company:
• The latter is an S.A. or a Lda. and shares or quotas were acquired before January 1st 1989: no CGT is due;
• PTT is not due on the sale of the S.A.;
• PTT (up to 6,5%) may be due on the sale of a Lda. when one of the quotaholders obtains 75% of the capital
or the number of holders is reduced to 2, husband and wife or civil law partners. So, 74% / 26% Lda.
ownership structures are common;
• The latter is an S.A. and shares have been acquired before January 1st 2002 (under some interpretations,
although there is a recent tax arbitration court decision stating that this specific exemption is no longer in
force): no CGT and no PTT are due.
 Other situations on the sale of the interest in the company (S.A., Lda.): 28% PIT CGT
(computed on half-income if the company is not listed and is a micro or small company);
or 25% CIT CGT.
19

20. Indirect sale of real estate – sale of the company
(CGT) (cont.)
 The Portuguese Sate Budget Law for 2018 has introduced new rules on
the Portuguese domestic taxation of CGT derived by non-Portuguese tax
residents with shares or similar interests in non-Portuguese tax resident
entities (whose value derives principally, directly or indirectly, in more
than 50%, from immovable property located in Portugal, and if such
relevant value threshold is met at any time during the 365 days preceding
the sale). (For more information on this regime please read our
Information Note: https://bit.ly/2VFhLXe).
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21. Gift of the interest in the company (ST / CIT)
 If actual share/quotaholders (Portuguese resident or non-resident, individual or
corporate) free transfer the interest in the Portuguese company by gift:
• to close family which are Portuguese resident (spouses, children, grandchildren,
parents and grandparents), an exemption from ST applies;
• to a beneficiary individual non-resident in Portugal - no ST is due;
• to other beneficiary individuals which are Portuguese resident a 10% rate applies;
• to a beneficiary which is a Portuguese company, a permanent establishment in
Portugal of a non-Portuguese tax resident company or even such last company in
the absence of a permanent establishment – CIT is due at a 21% rate, plus
Municipal and State surcharges if the beneficiary is a Portuguese company or a
permanent establishment; or at a 25% rate when the beneficiary is a non-
Portuguese tax resident company without a permanent establishment herein.
21

22. Gift of the interest in the company (ST / CIT)
(cont.)
 The free transfer by gift of a foreign company, even if its effective
management is not in Portugal and there is no permanent establishment
herein, but whose assets are predominantly composed by rights over real
estate in Portugal, is subject to CIT if the beneficiary is a Portuguese company,
a permanent establishment in Portugal of a non-Portuguese tax resident
company or even such last company in the absence of a permanent
establishment (at a 21% rate, plus Municipal and State surcharges if the
beneficiary is a Portuguese company or a permanent establishment; or at a
25% rate when the beneficiary is a non-Portuguese tax resident company
without a permanent establishment herein).
 The free transfer by gift of a foreign company, even towards individuals
Portuguese tax residents, is not liable to ST (assuming its effective
management is not in Portugal and that the real estate is not a permanent
establishment of the company), if the beneficiary is an individual which is not
tax resident in Portugal.
22

23. Change of the beneficial owner of the company
(CGT)
 Portuguese CGT applies since January 1st 2015 to gains in the case of
partition, liquidation, revocation or extinction attributed to beneficiaries
who are Portuguese tax residents and who were founders in fiduciary
structures.
 For founders / settlors who are non-Portuguese tax residents:
• If the effective management is not in Portugal (e.g. non-Portuguese resident
directors and share/quotaholders or members/partners are used at the level of
the foreign company and a foreign trust law and trustees are used) no PTT is
due if the disposal is made by changing the beneficial owner in a fiduciary
structures by the former founder / settlor / beneficiary;
23

24. Change of the beneficial owner of the company
(ST /CIT)
 The free transfer by gift of the beneficial ownership of a fiduciary structure:
• encompassing a Portuguese company (e.g. non-Portuguese resident share/quotaholders or
members/partners are used at the level of the company and a foreign trust law and trustees
are used) may not be territorially liable to ST, even if the beneficiary is a Portuguese tax
resident individual, but this will depend on the type of fiduciary structure;
• encompassing a foreign company whose effective management is not in Portugal (e.g. non-
Portuguese resident directors and share/quotaholders or members/partners are used at the
level of the company and a foreign trust law and trustees are used) and which has no
permanent establishment herein (namely because the real estate does not constitute one) is
not territorially liable to ST if the beneficiary is an individual which is not tax resident in
Portugal. If the beneficiary is a Portuguese tax resident individual in principle the free
transfer will still not be territorially liable to ST, but this will depend on the type of fiduciary
structure.
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25. Real Estate Tax Planning in Portugal
Proper legal advice is recommended before any decision is taken on this
subject. RPBA has an in-depth knowledge and expertise on real estate
taxation.
Should you require further information on this issue, want to book a
consultation or obtain our professional fees on this subject please e-mail
us (Ana Rita Pereira): rita@rpba.pt
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26. Recent Tax Recognition
 Chambers & Partners – Ricardo Band 2 / RPBA Band 3 (2018 / 2017 / 2016) and 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 (2018)
 Legal 500 – Ricardo Recommended Lawyer / RPBA Band 2 (2018) / RPBA Band 3 (2017 / 2016 / 2015 / 2014 / 2013)
 World Tax – Ricardo mentioned / RPBA Tier 3 (2018 / 2017 / 2016 / 2015 / 2014)
 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 (2018 / 2017 / 2016 / 2015 / 2014 / 2013 / 2012 / 2011)
 Corporate LiveWire – Ricardo chosen as the winner of the Finance Award for Tax Lawyer of the Year – Portugal (2017) / Ricardo chosen
as the winner of the Finance Award for Excellence in Tax Planning – Portugal (2016)
 Who’s Who Legal – Ricardo ranked as a top lawyer in the Corporate Tax Lawyers directory (2017 / 2016 / 2013) / Ricardo recognised as
a top lawyer in the Private Client practice area (2017)
 International Tax Review – Ricardo da Palma Borges and Ana Rita Pereira listed in the International Tax Review's Tax Controversy Leaders
guide (2018 / 2017) / Ana Rita Pereira listed in the Women in Tax Leaders guide (2018 / 2017)
 World Transfer Pricing – Ricardo mentioned / RPBA Tier 3 (2016 / 2015 / 2014)
 Expert Guides – Ricardo ranked as a top lawyer in the Tax Lawyers directory (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)
 Corporate Intl Magazine Global Award – RPBA Boutique Tax Law Firm of the Year – Portugal (2018 / 2017 / 2016 / 2014)
 Corporate Intl Magazine Legal Award – RPBA Boutique Tax Law Firm of the Year in Portugal (2015)
 Acquisition International Tax Award – RPBA Portuguese Tax Law Boutique Firm of the Year (2015)
 Acquisition International Legal Award – RPBA Boutique Law Firm of the Year – Portugal (2014)
 Tax Directors Handbook – Ricardo mentioned / RPBA Tier 3 (2015) 26

27. General warning, disclaimer, copyright
and authorised use
27
 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 April 10th, 2019.
 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 actual 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
solely for your internal business, provided that you do not modify its content in any way and that you do not
retain any copyright or other proprietary notices displayed on such content. You may not otherwise
reproduce, modify, distribute, transmit, post or disclose the content on this presentation without RICARDO da
PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L.’s prior written consent.

28. (+351) 212 402 743
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