Europe

Portugal

Tax


Portugal : AN INTRODUCTION

Contributed by PLMJ - A.M. Pereira, S. Leal, O. Martins, Júdice & Associados

Portugal offers a number of benefits that make it a choice destination for leading global companies and industries:
• Strategic location
• Gateway to wider markets
• Highly developed infrastructure and communications
• Highly skilled workforce and flexible human resources
• Business-friendly environment
• Top destination for global multinationals
• Competitive tax system

Portugal is located on Europe’s west coast making it a strategic platform for African and Portuguese-speaking countries as well as an effective gateway to wider markets. Portugal is an EU Member State and part of the eurozone. As such it enjoys benefits including free trade, absence of tariffs and free movement of labour and capital.

Portugal holds highly developed infrastructure, logistics and communications networks offering excellent national and international accessibility.

Portugal is a business-friendly environment. Within this context it is worth mentioning the new Golden Visa programme, which gives non-EU individuals the chance to obtain a visa permit and full access to the EU.

Highly talented workforce and adaptable HR make up the fourth factor. 42% of Portuguese people speak a second language.

Regarding business itself, most legal obligations have been eliminated or simplified, being possible to comply them in a fast way using the internet.

The Portuguese tax system is in line with most of its European counterparts and it follows most OECD guidelines, offering an extensive network of tax treaties (66).

At the domestic level, a Corporate Income Tax reform was recently enacted, which led the standard rate to drop to 23% (to drop to 17% in 2016), also featuring a new participation exemption regime, a patent box regime, an extended tax losses carry-forward period of 12 years and the tax depreciation of goodwill.

Capital gains made on the transfer of securities by foreign entities that are not domiciled in blacklisted jurisdictions, and which are not subject to indirect control of 25% or more by Portuguese residents, benefit from full tax exemption.

Portuguese legislation also features special debt securities tax rules offering a tax-free environment on interest and capital gains deriving from such debt securities.

A special personal taxation framework has been established for non-habitual residents, allowing individual taxpayers who become Portuguese tax residents and have not been taxed as such in the previous five years to enjoy, during a ten-year period, a reduced rate from 23.5% on employment and self-employment income from high value added activities performed in Portugal. In certain cases, foreign-sourced income may also be tax exempt.

A range of tax incentives are also available for investment in business R&D, corporate restructuring and investment projects deemed to be of interest to the country’s economic development and the reduction of regional imbalances.

Finally, it is worth noting that Portugal has implemented a tax arbitration system designed to achieve a quicker resolution of any tax disputes that may arise.

Tax - Portugal

 - 

Band 1 | Garrigues

第一等 |

Basic facts about the department 
- 2 partners
- 21 other qualified lawyers

What the team is known for Provides a wide range of tax services to domestic and international clients, from litigation to consultancy and transfer pricing. Noted for its international capacity and technical expertise.

Strengths (Quotes mainly from clients)
"The firm has a solid reputation across many sectors and I am happy with the quality it delivers." 

Work highlights Advised Santander Totta Seguros on the tax aspects of its agreement with Abbey Life Assurance for the reinsurance of its individual life risk portfolio.

Successfully represented Bansabadell in a litigation case concerning the alleged withholding of EUR5.5 million tax.

Notable practitioners  

Practice head Fernando Castro Silva is valued for his "experience and sense of responsibility towards the client in such a sensitive area as tax."

Significant clients Santander, Caixa Geral de Depósitos, Banco Espírito Santo.

第一等 |

Basic facts about the department 
- 2 partners
- 19 other qualified lawyers

What the team is known for Maintains an exceptional reputation for its expertise in domestic and international tax matters including litigation, arbitration and transfer pricing. Noted for its strong presence in lusophone Africa.

Strengths (Quotes mainly from clients)
"A discreet, very solid and well-rounded team; it is my first option for tax."

Work highlights Assisted EDP with several tax litigation and arbitration cases.

Notable practitioners  

Francisco de Sousa da Câmara is considered one of the top tax practitioners in the country. He co-ordinates the Lisbon and Funchal teams.

António Lobo Xavier co-ordinates the team in Porto and is said to be "one of the best for tax." 

Clients enjoy working with Nuno Oliveira Garcia and admire his "strong technical skills." 

Sources describe associate Bruno Santiago as "the best of the new generation. He is dynamic and not afraid of presenting new ideas."

Significant clients Grupo Modelo, ING-DIBA, EDP - Energias de Portugal, HPP. 

第二等 |

Basic facts about the department 
- 6 partners
- 15 other qualified lawyers

What the team is known for Sizeable team that covers contentious and transactional tax matters, and has vast experience in corporate tax and transfer pricing. Praised for its pragmatism and technical prowess.

Strengths (Quotes mainly from clients)
"The lawyers know how to translate law into business." 

Work highlights Assisted Amil Participações with the tax aspects of HPP Health Group's privatisation.

Represented cement producer Secil in several litigation and arbitration proceedings.

Notable practitioners  

Clients enjoy working with Miguel Teixeira de Abreu"He's got both feet on the ground and treats us as equal partners." 

Duarte de Athayde handles tax matters as part of a mixed practice which also covers corporate, commercial and real estate law.

Sources say Maria Dulce Soares is "excellent; she delivers high-quality work." 

第二等 |

Basic facts about the department 
- 2 partners
- 12 other qualified lawyers

What the team is known for Offers outstanding tax expertise in Portugal and internationally. Handles litigation, transfer pricing, financial and general corporate tax issues.

Strengths (Quotes mainly from clients)
"It combines legal knowledge with financial expertise, which adds great value to its services." 

Notable practitioners  

Diogo Ortigão Ramos is noted for his exceptional dedication to clients and business-minded approach.

Tânia de Almeida Ferreira is particularly sought for her expertise in real estate tax. 

Band 2 | Linklaters

第二等 |

Basic facts about the department 
- 3 other qualified lawyers

What the team is known for Exceptional experience in cross-border transactions and projects across lusophone Africa, with additional expertise in litigation and arbitration. Praised for its commercial and proactive approach.  

Strengths (Quotes mainly from clients)
"The lawyers are responsive, pragmatic and deliver amazing client service. I would recommend them without any hesitation."

"Creative, solution-oriented and assertive. The firm co-ordinates cross-border matters extremely well."

Work highlights Assisted Aggreko with the tax aspects of the construction and operation of a temporary power plant which will supply power to South Africa's Eskom and Mozambique's EDM.

Advised Portucel on the tax issues associated with a high-yield bond issue.

Notable practitioners  

Practice head Rui Pereira Camacho Palma has extensive experience handling tax matters in Mozambique. Sources say he is "client-focused, pragmatic and commercial." 

Ricardo Reigada Pereira focuses on tax planning and litigation. He is noted for his attention to detail and excellent communication and negotiation skills.

Significant clients Aggreko, Portucel, Nestlé, Clearstream International.

第二等 |

Basic facts about the department 
- 4 partners
- 6 other qualified lawyers

What the team is known for Advises on the full range of tax matters from transactions to litigation and fraud cases. The firm has offices in Lisbon, Porto and the Algarve, and is also highly active in lusophone Africa, notably Angola and Cabo Verde. 

Strengths (Quotes mainly from clients)
"It is a pleasure to work with these lawyers; they have deep expertise and provide clear and structured advice."

"All the lawyers know what's happening on the case and work really well as a team. It sets them apart from others in the market."

Work highlights Represented Swiss wealth management company Akoya Management in tax fraud proceedings involving dozens of Portuguese clients.

Assisted ANA - Aeroportos de Portugal with the tax due diligence prior to its privatisation.

Notable practitioners  

Tax expert João Magalhães Ramalho impresses clients with his "down-to-earth and proactive style. He's really approachable and provides straightforward advice."

Tax litigation specialist Serena Cabrita Neto recently joined the team as a partner. She led on ANA - Aeroportos de Portugal's due diligence.

Nuno da Cunha Barnabé is acclaimed for his "cautious and detail-oriented" approach.

Miguel Reis is a dedicated tax lawyer based in Porto. He advises high net worth individuals with estate planning and structuring.

Significant clients Refriango Group, Eurofin Group, Capgemini, Future Healthcare.   

第二等 |

Basic facts about the department 
- 1 partner
- 9 other qualified lawyers

What the team is known for Best known for its expertise in the tax aspects of M&A transactions and restructurings. Additional experience in wealth management.

Strengths (Quotes mainly from clients)
"It delivers high-quality work at all levels, from juniors to partners." 

Work highlights Advised ECS Capital on the tax issues arising from the acquisition of distressed real estate assets and companies.

Notable practitioners  

Filipe Romão leads the team. Sources say he is "an outstanding professional with in-depth knowledge of Portuguese tax issues." 

Miguel Durham Agrellos heads the firm's Porto office. His expertise extends to corporate, non-resident and M&A taxation, as well as international tax planning, wealth management and litigation.

Sources describe António Castro Caldas as "highly dedicated, fast and solution-minded." 

Senior associate Claudia Reis Duarte earns praise for her prowess in tax litigation. "She is young but already a star in tax litigation. She is assertive, always available and a pleasure to work with. She adds a lot of value to the team," say clients.

Significant clients CIMPOR, ECS, Swiss Life, Galp Energia.

第三等 |

Basic facts about the department 
- 2 partners
- 6 other qualified lawyers

What the team is known for Tax is one of the key practices at this firm, covering a wide range of matters from transactional to contentious. Its association with DLA Piper has increased its cross-border work.

Strengths (Quotes mainly from clients)
"A strong team. The lawyers work well together and complement each other. They're upfront, open and excellent negotiators."

Work highlights Assisted GDF SUEZ with EUR30 million litigation pertaining to property tax.

Represented retail company Sonae Sierra in several tax litigation cases concerning municipal charges over the Colombo and Vasco da Gama shopping centres.

Notable practitioners  

António Moura Portugal is noted for his "ability to combine academic knowledge and pragmatism."

Clients point to Nuno Azevedo Neves' dedication and negotiation skills as his main strengths.

Significant clients Air France - KLM, Altadis Group, APREN, Cisco Systems. 

第三等 |

Basic facts about the department 
- 1 partner
- 1 other qualified lawyer

What the team is known for A well-regarded boutique handling the tax aspects of M&A transactions as well as litigation. Clients include financial institutions and companies in the construction, leisure and consumer products sectors.  

Strengths (Quotes mainly from clients)
"Great teamwork. I'd highlight the lawyers' technical skills, proactivity and innovative approach."

Notable practitioners

Practice head António Rocha Mendes impresses clients with his experience and technical know-how.

Band 3 | CMS

第三等 |

Basic facts about the department 
- 2 partners
- 4 other qualified lawyers

What the team is known for Working closely with the firm's corporate department, this team has a strong focus on transactional tax issues. Also noted for its litigation expertise, particularly in cases against public entities.

Strengths (Quotes mainly from clients)
"Highly technical and solicitous." 

Work highlights Represented private television operator TVI in a tax litigation case against the Portuguese state before the ECJ.

Advised Mercedes-Benz Financial Services Portugal on legal proceedings against the Portuguese state.

Notable practitioners  

US-qualified Patrick Dewerbe focuses on cross-border matters. Clients describe him as "diligent, knowledgeable and straightforward." 

Nuno Pena focuses his practice on civil, commercial and corporate law as well as tax litigation.

Significant clients VINCI Concessions, Ongoing Group, Venevision International, Rubicon.

第三等 |

Basic facts about the department 
- 1 partner
- 10 other qualified lawyers

What the team is known for Outstanding tax boutique with a strong focus on tax litigation and the internationalisation of Portuguese and foreign companies. Praised for its outstanding technical expertise.

Strengths (Quotes mainly from clients)
"A detail-oriented, rigorous team which always keeps clients updated."

Notable practitioners  

Sources highlight Rogério Fernandes Ferreira's "combination of academic expertise and practical experience" as a key strength. 

第三等 |

Basic facts about the department 
- 1 partner
- 7 other qualified lawyers

What the team is known for An esteemed tax boutique providing a wide range of related services, with a particular focus on income and real estate tax as well as litigation.

Strengths (Quotes mainly from clients)
"The team is very detail-oriented and studious, with deep knowledge of restructurings and corporate law." 

Notable practitioners  

Specialist tax lawyer Ricardo da Palma Borges is praised for combining "high technical abilities with creativity, pragmatism and business sense." 

第三等 |

Basic facts about the department 
- 1 partner
- 12 other qualified lawyers

What the team is known for Handles a large range of tax matters on behalf of financial institution, construction, telecoms and pharmaceutical clients. Particularly active in restructurings, financial transactions and the internationalisation of domestic companies.

Strengths (Quotes mainly from clients)
"We are very happy with the service. The lawyers approach matters from a global point of view and anticipate any developments."

Work highlights Advised José de Mello Investimentos on its bid over Brisa.

Advised DaVita on the tax aspects of its acquisition of several haemodialysis clinics in Portugal and Poland. 

Notable practitioners  

Sources highlight Tiago Marreiros Moreira's strategic approach and deep knowledge of EU tax issues as distinguishing qualities.

Conceição Gamito earns praise for her expertise on VAT issues.

Joaquim Lampreia leads the tax litigation group. Clients say he is "pragmatic and efficient." 

Significant clients PT Group, Andrade Gutierrez Group, Deutsche Bank, Generg.

第四等 |

Basic facts about the department 
- 3 partners
- 15 other qualified lawyers

What the team is known for Attracts a diverse set of clients thanks to its strong focus on tax matters including VAT, consultancy and litigation.

Strengths (Quotes mainly from clients)
"The team has always given us good advice; it is very reliable." 

Work highlights Advised medical diagnostics company Labco on the tax issues associated with its EUR100 million senior secured notes issue.

Notable practitioners  

Department head Tiago Caiado Guerreiro is a dedicated tax lawyer and lecturer.

Significant clients Olympus, Impulsionatis, United Continental Airlines, CNP BVP.

Band 4 | CCA Advogados

第四等 |

Basic facts about the department 
- 3 partners
- 4 other qualified lawyers

What the team is known for Handles the tax issues of restructurings and acquisitions, as well as litigation and arbitration. The firm is a member of the WTS Alliance and Ontier network, and has overseas links in Shanghai, Brazil, Spain and lusophone Africa.

Strengths (Quotes mainly from clients)
"The team gives practical solutions and great work at a reasonable price." 

Work highlights Represented AON Motor in a tax arbitration case.

Assisted GAP Pharmacies Group with its restructuring. 

Notable practitioners

Carla Matos is key contact for the practice.

Significant clients TIMWE, Hawas, Cofina, WTS Alliance.

第四等 |

Basic facts about the department 
- 2 partners
- 3 other qualified lawyers

What the team is known for Provides tax advice and support to both businesses and individuals, with extensive experience in litigation.

Strengths (Quotes mainly from clients)
"Vast knowledge and great-quality work. I have a great impression of the team." 

Notable practitioners  

Tax expert João Espanha is, according to clients, "an excellent adviser, a great strategist and always available. He's highly practical and solution-oriented." 

第四等 |

Basic facts about the department 
- 1 partner
- 4 other qualified lawyers

What the team is known for Extensive experience in tax consultancy and litigation. Noted for its strong presence in lusophone Africa, with corresponding offices in Angola and Mozambique.

Strengths (Quotes mainly from clients)
"The lawyers are available, assertive and business-oriented. They give straightforward advice." 

Work highlights Represented International Ceramic Group in a tax litigation case concerning transfer pricing.

Assisted Medinfar with the tax aspects of its restructuring.

Notable practitioners 

Tax specialist Diogo Bernardo Monteiro comes particularly recommended for contentious matters: "He keeps clients informed and makes the information accessible to us, speaking in simple terms."

Significant clients Braun, DaimlerChrysler, Datacomp Web Technologies.

第四等 |

Basic facts about the department 
- 2 partners
- 3 other qualified lawyers

What the team is known for Advises on a broad range of tax matters including VAT, stamp duty and international taxation. Clients include energy, healthcare and telecoms companies.

Notable practitioners  

Gonçalo Leite de Campos is a prominent tax lawyer. Sources describe him as "very proactive and highly skilled. He has a global view of matters that allows him to see beyond the legal issue at hand."

Since publication, Gonçalo Leite de Campos has joined Gonçalo Leite de Campos & Associados

Band 5 | AAA Advogados

第五等 |

Basic facts about the department 
- 2 qualified lawyers

What the team is known for The team works closely with the firm's corporate and dispute resolution departments to represent clients in tax litigation and advise on corporate finance and restructuring deals.

Work highlights Assisted supermarket chain Dia and media group Omnicom with tax litigation.

Notable practitioners  

André Gonçalves and Gabriela Rodrigues Martins are the key contacts for the practice.

Significant clients Volkswagen Autoeuropa, Dia Portugal Supermercados, Omnicom Portugal, ATEC - Associação de Formação para a Indústria. 

第五等 |

What the team is known for Combines tax and financial law expertise to assist clients with a wide range of issues including litigation and planning.

Notable practitioners  

António Gaio earns praise from market commentators for his long-standing experience in tax matters.

第五等 |

Basic facts about the department 
- 2 partners
- 3 other qualified lawyers

What the team is known for Bringing a boutique approach to tax, this team handles complex structuring work for banks and corporate clients. Recent mandates include M&A, financing and real estate transactions.

Strengths (Quotes mainly from clients)
"The firm fits our needs and offers excellent value for money."

Work highlights Advised Arrow Global on the tax issues arising from its acquisition of a loan portfolio.

Notable practitioners

Practice head André Dias is the main contact. 

Significant clients Altice, Riverside/Tensator Group, Onitelecom, GDF SUEZ. 

第五等 |

What the team is known for Provides a wide range of consultancy and contentious tax services from its offices in Lisbon, Faro and Ponta Delgada. Acts on behalf of automotive, insurance and retail clients, as well as high net worth individuals.

Strengths (Quotes mainly from clients)
"The team has solid knowledge of tax law, and is firmly committed to its clients."

Work highlights Represented Liberty in claims pertaining to double tax treaties and the carrying forward of losses.

Assisted GM with real estate tax issues and litigation.

Notable practitioners  

Sources speak highly of practice head Mário da Rosa Amaral"He is cautious and provides solid advice which considers the business aspects."

Significant clients Refridge, GM, Moviflor, Liberty Mutual.

Band 5 | SRS Advogados

第五等 |

Basic facts about the department 
- 1 partner
- 2 other qualified lawyers

What the team is known for A compact but prestigious practice that covers the tax issues of securitisations and derivatives transactions, restructurings and financings, as well as litigation. Noted for its responsiveness and client-oriented approach.

Strengths (Quotes mainly from clients)
"The lawyers work well as a team. They are knowledgeable, efficient, responsive and available."

What's new José Pedroso de Melo joined the team in October 2013. 

Work highlights Represented Galp in VAT litigation.

Advised Banque Privée Espírito Santo on the tax aspects of several transactions and financial products.

Notable practitioners

João Maricoto Monteiro has vast experience in corporate crime, tax litigation, planning and restructuring. Sources say: "He is the best; very client and business-oriented."

Tax expert José Pedroso de Melo joined the team in October 2013. He is praised by sources as having "a lot of common sense and experience."

In addition to being an experienced tax lawyer, Paula Rosado Pereira is also a professor of tax law at the University of Lisbon.

Significant clients Galp Energia, Banque Privée Espírito Santo, Banco do Brasil, Copisa.

第五等 |

What the team is known for Covers tax consultancy, litigation, restructurings and M&A. It often operates in other EU countries, Brazil and lusophone Africa.

Strengths (Quotes mainly from clients)
"The lawyers are all very available."

Notable practitioners 

Leonor Xavier is particularly well versed in issues concerning Brazil and the Madeira Free Trade Zone.

Other Ranked Lawyers 其他上榜律师

António Fernandes de Oliveira of AFDO-adv focuses his practice on tax law and has a wealth of experience in litigation and consultancy.

João Marques Pinto of Pedro Pinto, Bessa Monteiro, Reis, Branco, Alexandre Jardim & Associados - Sociedade de Advogados, RL handles tax litigation and planning.

Rui Barreira of Rui Barreira, Magalhães Correia, Teresa Carregueiro e Gorjão Henriques is recognised as one of the leading tax lawyers in the market.

Foreign Experts

Foreign Experts are individuals with expertise in a different jurisdiction to the one they are based in. These individuals are particularly highly regarded for international and cross-border work. Usually, they will be identified in the jurisdiction in which they are based and in their country of expertise.

Senior Statesman

A 'Senior Statesman' is a lawyer who no longer works hands-on with the same intensity but who, by virtue of close links with major clients, remains pivotal to the firm’s success.

Eminent Practitioners

'Eminent Practitioners' are highly influential lawyers in a particular practice area who, due to managerial or client relationship commitments, are less active in day-to-day work but remain key players in the team.

Other Noted Practitioners

Other Noted Practitioners are individuals who have not yet been ranked but are seen to be active and accomplished in this area of law.

Other Noted Firms

Other Noted Firms are firms that have not yet been ranked but are seen to be active and accomplished in this area of law.