Portuguese Corporate Income Tax ('Imposto sobre o Rendimento das Pessoas Colectivas' or IRC) is applicable to either the income obtained by resident or non-resident entities. Regarding non-resident entities it taxes only their income obtained in Portuguese territory, as to the resident entities it taxes their global income, either from internal or external source. The taxation period is normally the civil year, but it can be adopted a different one in some special cases. Transfer Pricing rules apply in Portugal. Thin Capitalization Rules apply only to entities resident outside the UE. Resident entities are normally taxed through the delivery of the respective Income Statement ('Declaração Modelo 22') for their global income. Non-resident entities may be taxed either by definitive withholding tax or are obliged to the delivery of the Declaração Modelo 22 in some situations (namely in case of capital gains).

Portuguese VAT is a consumption tax, applicable to every transactions of goods, rendering of services, importations and intracomunitary acquisition of goods. It has a reasonable degree of harmonization towards EU legislation. There are several exemptions and tax reductions available , meaning that a case by case analysis of every operation is needed in order to apply the most suitable tax frame.

Stamp Duty Tax is levied, namely, on financial, insurance and real estate operations, share capital increases and inheritance transmissions.

Property Transfer Tax is supported by the respective buyer entity, every time an asset concerning real estate located in the Portuguese territory is acquired.

Real Estate Municipal Tax is an annual tax that must be paid by whom is the respective owner of the real estate on the 31st of December of the respective year. Tax rates are determined by each municipe.

Income tax rates applicable to residents in Azores are, in general terms, 30% (for corporate entities) and 20% (for individuals), lower than equivalent tax rates applied in mainland.

Reduced VAT rates are applicable to operations considered localized in Açores territory.

There are several tax benefits available to entities investing in Açores, namely exemptions on profits reinvested or contractual tax benefits for bigger investment projects (namely exemptions on SDT, on Property Tax and additional deductions on IRC).

Income tax rates applicable to residents on Açores are, in general terms, 30% (for corporate entities) and 20% (for individuals), lower than equivalent tax rates applied in mainland.

Reduced VAT rates are applicable to operations considered localized in Açores territory.

There are several tax benefits available to entities investing in Madeira, namely exemptions on profits reinvested or contractual tax benefits for bigger investment projects (namely exemptions on SDT, on Property Tax and additional deductions on IRC).

Madeira Free Zone is a restricted area where companies may develop their activity and benefit from one of the most favourable tax regimes in the European Jurisdictions. In addition it is a tax regime accepted by the EU authorities.

Special Tax Regime on MFZ is applicable to entities established on that same territory, regarding the respective income obtained outside the Portuguese territory."

MFZ is a territory located in Madeira, so the same reduced VAT rates applicable to Madeira territory are applicable to MFZ. There any be additional exemptions or other benefits applicable to MFZ. A case by case analysis should be adopted."

General exemption on STD on the operations executed by these entities. General IRC exemption applicable to income related, namely , to royalties and services rendering paid to non-resident entities."

There are three major different types of Investment Funds, considering the tax regime in Portugal: - Securities Investment Funds (FIM); - Real Estate Investment Funds (FII); - Funds of Funds (FF). Investment Funds are a very tax efficient vehicle for some kind of investments, given its global tax frame, specially in some particular cases, like the Urban Real Estate Rehabilitation investments made in the historical city centres. There also additional tax benefits for these kind of investment vehicles, namely, in terms of property tax. Regarding Investment Funds Tax regime in Portugal there are two levels of taxation: - Taxation of the Funds' income; - Taxation of the Unit holders' income (investors).

Either the employer and the employee entities are obliged to SS contributions."

Either the corporate entities and board members individuals are obliged to SS contributions."