Stamp Tax Portugal
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Stamp Tax


Stamp Tax

  • 1. Tax basis
  • 2. Rates
    Tax basis Rate (%)
    Acquisition of ownership or other rights on real estate (or consideration or donation). 0.8
    Gratuitous acquisition of goods by individuals (gift or inheritance), including adverse possession. 10
    Letting or sub-letting of real estate (applied on the amount of first monthly rent) 10
    Guarantees, regardless of their nature or form, except if materially accessory and simultaneously to contracts subject to Stamp Tax under other rule:

    - Less than one year (per month or fraction);
    - One or more years;
    - Five or more years or without term.




    0.04
    0.5
    0.6
    Use of credit:

    -Less than one year (per month or fraction);
    - One or more years;
    - Five or more years;
    - Revolving credit facilities (credit used in the form of current account, overdraft or any other form in which the maturity is not determined or non-determinable) - per month on the average monthly debt balance daily assessed (dividing the sum of the daily debt balance by 30).


    0.04
    0.5
    0.6
    0.04

    Operations performed by or through credit and financial institutions:

    - Interest;
    - Premiums and interest due on promissory notes;
    - Commissions on given guarantees;
    - Other commissions for financial services.


    4
    4
    3
    4
    Net asset value of undertakings for collective investment (UCIs) - due on a quarterly basis.

    - UCIs investing only in money market instruments and deposits;
    - Other types of UCIs (including real estate funds and companies).



    0.0025%
    0.0125%

  • 3. Payment
    Countries Entry into force Rates
    - - Dividends  Interest Royalties
    South Africa 22/10/2008 10/15 (a) 10 10
    Germany 08/10/1982 15 10/15 (g) 10
    Andorra 23/04/2017 5/15 (o) 10 5
    Angola 22/09/2019 8/15 (a) 10 5
    Saudi Arabia 01/09/2016 5/10 (o) 10 8
    Algeria 01/05/2006 10/15 (a) 15 10
    Austria 28/02/1972 15 10 5/10 (b)
    Barbados 07/10/2017 5/10 (a) 10 5
    Bahrein 01/11/2016 10/15 (a) 10 5
    Belgium 19/02/1971 - 05/04/2001 15 15 10
    Brazil 01/01/2000 10/15 (a) 15 15
    Bulgaria 18/07/1996 10/15 (a) 10 10
    Cape Verde 15/12/2000 10 10 10
    Canada 24/10/2001 10/15 (a) 10 10
    Chile 25/08/2008 10/15 (a) 5/10/15 (c) 5/10 (d)
    China 08/06/2000 10 10 10
    Cyprus 01/08/2013 10 10 10
    Colombia 30/01/2015 10 10 10
    South Korea 21/12/1997 10/15 (a) 15 10
    Ivory Coast 18/08/2017 10 10 5
    Croatia 28/02/2015 5/10 (a) 10 10
    Cuba 28/12/2005 5/10 (a) 10 5
    Denmark 01/01/2003 10 10 10
    United Arab Emirates 22/05/2012 5/15 (o) 10 10
    Slovakia 01/01/2005 10/15 (a) 10 10
    Slovenia 01/01/2005 5/15 (a) 10 5
    Spain 28/06/1995 10/15 (a) 15 5
    United States of America 01/01/1996 5/15 (a) 0/10 (j) 10
    Estonia 01/01/2005 10 10 10
    Ethiopia 09/04/2017 5/10 10 5
    Finland 14/07/1971 10/15 (a) 15 10
    France 18/11/1972 15 10/12 (f) 5
    Georgia 18/04/2016 5/10 (a) 10 5
    Greece 01/01/2003 15 15 10
    Guinea-Bissau 05/07/2012 10 10 10
    Hong Kong 03/06/2012 5/10 (o) 10 5
    Hungary 08/05/2000 10/15 (a) 10 10
    India 05/04/2000 10/15 (a) 10 10
    Indonesia 11/05/2007 10 10 10
    Ireland 11/07/1994 -18/12/2006 15 15 10
    Iceland 01/01/2003 10/15 (a) 10 10
    Israel 18/02/2008 5 (a) / 10 (n) / 15 10 10
    Italy 15/01/1983 15 15 12
    Japan 28/07/2013 5/10 (p) 5/10 (p) 5
    Kuwait 05/12/2013 5/10 (p) 10 10
    Latvia 07/03/2003 10 10 10
    Lithuania 26/02/2003 10 10 10
    Luxemburg 30/12/2000 10 10 10
    Macau 01/01/1999 10 10 10
    Malta 01/01/2003 10/15 (a) 10 10
    Morocco 27/06/2000 10/15 (a) 12 10
    México 09/01/2001 10 10 10
    Mozambique 01/01/1994 - 07/06/2008 15 10 10
    Moldavia 18/10/2010 5/10 (a) 10 8
    Montenegro 07/12/2017 5/10 (o) 10 5/10 (q)
    Norway 15/06/2012 5/15 10 10
    Panamá 10/06/2012 10/15 (o) 10 10
    Pakistan 04/06/2007 10/15 (a) 10 10
    Peru 12/04/2014 10/15 10/15 10/15
    Poland 04/02/1998 10/15 (a) 10 10
    Qatar 04/04/2014 5/10 10 10
    United Kingdom 20/01/1969 10/15 (a) 10 5
    Czech Republic 01/10/1997 10/15 (a) 10 10
    Romania 14/07/1999 10/15 (a) 10 10
    Russia 01/01/2003 10/15 (a) 10 10
    San Marino 03/12/2015 10/15 (a) 10 10
    São Tome e Príncipe 12/07/2017 10/15 (a) 10 10
    Senegal 20/03/2016 5/10 (a) 10 10
    Singapura 26/12/2013 10 10 10
    Sweden 01/01/2000 10 10 10
    Switzerland 17/12/1975 5/15 (a) 10 5
    Oman 26/07/2016 5/10/15 (o) 10 8
    Tunisia 21/08/2000 15 15 10
    Turkey 18/12/2006 5/15 (a) 10/15 (i) 10
    Ukraine 01/01/2003 10/15 (a) 10 10
    Uruguay 13/09/2012 5/10 (a) 10 10
    Venezuela 08/01/1998 10/15 (a) 10 10/12 (k)
    Vietnam 09/11/2016 5/10/15 (o) 10 10/7,5

    (*) The reduced rates are applicable either by relief at source mechanism or refund reclaim provided the beneficiary presents the necessary forms (21-RFI to 24-RFI), duly completed (but no need to be authenticated by the respective tax authorities) and a tax residence certificate of the recipient of the income.

    (a) Reduced rate whenever the beneficiary is a company that holds at least 25% of the subsidiary’s share capital (two years holding period) and 15% in the remaining cases. In the case of Andorra and Saudi Arabia, the shareholder percentage criterion is limited to 10% of the capital of the company which pays the dividens. In the case of Chile, Cuba, Slovenia, Spain, Finland, Moldova, Norway, UK and Switzerland, there is no minimum holding period required. In the case of the UK, the shareholding percentage criterion is replaced by voting rights. In the case of Venezuela, there is no requirement on a minimal capital shareholding on the company of the other Contracting State. In the case of Barbados, Bahrein, Croatia, United Arab Emirates, Ethiopia, Georgia, Moldavia and Uruguay, there is no requirement on a minimum shareholding period. In the case of Angola, the minimum holding period is 365 days.

    (b) When the company holds more than 50% of the share capital.

    (c) 5% on bonds or securities that are regularly and substantially traded on a recognized securities market, 10% on loans granted by banks and insurance companies or on sale on credit and 15% on the remaining cases.

    (d) 5% on royalties for the use of, or the right to use, any industrial, commercial or scientific equipment. 10% on the remaining cases.

    (e) 10% whenever the parent company controls more than 50% of the subsidiary’s share capital. 5% on the remaining cases.

    (f) 10% for interest derived from bonds issued in France on or after 1/1/1965; 12% on the remaining cases.

    (g) 10% for interest on loans granted by a bank. When the interest is derived from Portugal, the 10% rate is only applicable if the operation for which such loans are granted is officially deemed to be of economic or social interest for Portugal.

    (h) 10% on interest paid by companies resident in a Contracting State, where interest paid is considered as a deductible cost, to a financial establishment resident in the other Contracting State. 15% on the remaining cases.

    (i) 10% for interest paid on a loan made for a period of more than two years.

    (j) 0% on interest on a long-term loan (5 or more years) granted by a bank or other financial institution that is a resident of the other Contracting State

    (k) 10% for royalties concerning technical assistance.

    (l) Many treaties provide for specific withholding tax exemptions of on interest, namely when interest is paid by and to a State, local authority, central bank, or export credit institutions and when interest is pain in relation to sales on credit.

    (m) The treaty does not apply to exempt Luxembourg 1929 holding companies.

    (n) 10% whenever the beneficial owner is a company that holds directly at least 25% of the paying company’s capita. Furthermore, this company must be a resident of Israel and the dividends are paid deriving from Israeli-sourced taxable income subject to a lower rate when compared to the Israeli CIT tax rate.

    (o) If the beneficial owner is a company (unless it is a partnership) which holds directly at least 10% of the share capital of the entity paying dividends. In the case of Montenegro, the percentage is 5%. In the case of Vietnam, it is applicable a rate of 5% if the beneficial owner is a company which holds, directly, at least 70% of the capital of the entity paying the dividends.

    (p) 5% whenever the beneficial owner is a company (unless it is a partnership) which holds directly for an uninterrupted period of 12 months (i) 10% of shareholding with voting rights of the distributing company which is a resident of Japan, or (ii) 10% of the share capital of the company distributing dividends which is a resident of Portugal.

    (q) 5% for royalties related with any copyright of literary, artistic or scientific work and 10% for royalties related with patents, trade-marks, design or model, plan, secret formula or process, or for information concerning industrial, commercial or scientific experience.

    (r) 10% for royalties and 7,5% for income generated from technical fees (managerial, technical or consultancy).


    Annex 2

    [Portuguese Blacklisted jurisdictions]

    American Samoa

    Costa Rica

    Labuan

    Anguilha

    Djibouti

    Lebanon

    Antigua and Barbuda

    Dominica

    Liberia

    Aruba

    Falkland Islands or Malvinas

    Liechtenstein

    Ascension Island

    Fiji Islands

    Maldive Islands

    Bahamas

    French Polynesia

    Marshall Islands

    Bahrain

    Gambia

    Netherlands Antilles

    Barbados

    Gibraltar

    Northern Mariana Islands

    Belize

    Grenada

    Niue Island

    Bermuda

    Guam

    Norfolk Island

    Bolivia

    Guyana

    Pacific Islands

    British Virgin Islands

    Honduras

    Palau Islands

    Brunei

    Hong Kong

    Panama

    Cayman Islands

    Isle of Man

    Pitcairn Island

    Channel Islands

    Jamaica

    Porto Rico

    Christmas Island

    Jordan

    St Vicente and the Grenadines

    Cocos (Keeling)

    Kingdom of Tonga

    Sultanate of Oman

    Cook Islands

    Kiribati

    Svalbard

    Qatar

    Kuwait

    Swaziland

    Queshm Island

    United Arab Emirates

    Tokelau

    Saint Helena

    United States Virgin Islands

    Trinidad and Tobago

    Saint Kitts and Nevis

    Vanuatu

    Tristan da cunha

    Saint Lucia

    Yemen Arab Republic

    Turks and Caicos Islands

    Saint Pierre and Miquelon

    Uruguay

    Tuvalu

    Samoa

    Mauritius

     

    San Marino

    Monaco

     

    Seychelles

    Monserrat

     

    Solomon Islands

    Nauru

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