The article outlines how corporate income tax (CIT) and VAT planning, vehicle selection, and structuring choices can materially affect returns on Portuguese real estate investments. It highlights Portugal’s progressive CIT rate reduction, the special tax regime for SICs, and the conditions under which VAT exemptions can be waived to enable VAT recovery while preserving CIT benefits.
The rate will drop from 20% in 2025 to 17% in 2028.
SICs face a 10% withholding tax on distributions (0% if investing in securities), while standard SPVs are subject to 25%.
The waiver applies when both parties are VAT‑able persons with a deduction right over 80% and the asset has been used exclusively for VAT‑able activities.
SICs must pay a stamp duty of 0.0125% on their net asset value each year.
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Bloomberg Tax · about 4 hours ago
An Advocate General for the European Court of Justice has opined that transfer price adjustments made by Stellantis Portugal to dealership sales are not subject to VAT, as they are considered alien to VAT law. The opinion, issued Thursday, is not binding on the court, and the ECJ decision remains unscheduled. The case centers on Stellantis's retroactive price adjustments to ensure a basic profit margin for local dealerships.
Pikon · 7 days ago
Portugal has extended its mandatory B2G e‑invoicing regime to all business sizes, with key deadlines moving into 2026 and 2027. The new rules require QR codes, ATCUD codes, and eventually Qualified Electronic Signatures (QES) for electronic invoices, while the eSPAP platform remains the official submission channel. SAP ECC and S/4HANA users must adopt the eDocument Cockpit and integration flows to remain compliant.
LinkedIn · 9 days ago
The Portuguese Tax Authority (AT) has clarified the rules for input VAT deduction on electric and plug‑in hybrid vehicles in Oficio Circulado n.º 25088. Key points include VAT liability on private use, non‑deductibility of maintenance expenses, and a 50% deduction for bi‑fuel vehicles. These changes affect how companies account for vehicle-related VAT and may require procedural adjustments.
Bailiwick Express · 42 minutes ago
Guernsey officials discuss that any future increase to the proposed 5% GST would require a two‑thirds super majority under the island’s Reform Law. The introductory rate would be 5% if retail food sales are included, or 6% otherwise, and a 6% rate would be needed to raise about £50 million net. The proposal aims to keep the tax broad and simple to limit future rate hikes.
Macfarlanes · about 4 hours ago
The UK Supreme Court ruled on 15 January 2026 that VAT on professional costs incurred in connection with a VAT‑exempt share disposal is not recoverable, rejecting any general fundraising exception. The decision applies to corporate groups where the parent provides taxable management services to a subsidiary, confirming that share sales remain within the scope of VAT but exempt, and that VAT grouping does not alter this treatment. Taxpayers must therefore plan for non‑recoverable transaction costs when restructuring or disposing of subsidiaries.
Bloomberg Tax · about 6 hours ago
On December 23, 2025, Hungary enacted Decree No. 45/2025, setting new transfer‑pricing documentation thresholds. The decree requires local files for related‑party transactions above 150 million HUF and master files for those above 500 million HUF, while offering simplified documentation for low‑value services.
