News Share

The Tax Hub

Daily Tax Newsletter


17 May 2019

Responsive image

Protocol to Tax Treaty between Portugal and Sweden Signed

Sweden's Ministry of Finance has announced the signing of an amending protocol to the 2002 income tax treaty with Portugal on 16 May 2019. Changes made by the protocol include:

  • The update of the preamble in line with BEPS Standards;
  • The amendment of Article 2 (Taxes Covered) with respect to Portuguese taxes, which includes individual income tax, corporate income tax, the additional tax on corporate income;
  • The amendment of Article 3 (General Definitions) with respect to the competent authority for Portugal;
  • The replacement of Article 5 (Permanent Establishment) in line with BEPS standards;
  • The replacement of the reference to EU Council Directive 90/435/EEC contained in Article 10 Dividends with a reference to EU Council Directive 2011/96/EU on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States;
  • The amendment of Article 11 (Interest) with respect to the withholding tax exemption for interest paid on loans granted by specified banks/institutions;
  • The amendment of Article 13 (Capital Gains) to provide that gains from the alienation of shares or similar rights deriving more than 50% of their value directly or indirectly from immovable property situated in a Contracting State at any time in the 365 days preceding the alienation may be taxed in that State;
  • The replacement of Article 16 (Directors' Fees) with updated provisions;
  • The amendment of Article 18 (Pensions) to provide that pensions earned in Sweden will be taxable in Sweden if not taxed in Portugal;
  • The amendment of Article 22 (Elimination of Double Taxation) with respect to Portugal, to include that Portugal still generally applies the credit method, except to the extent that these provisions allow taxation in Sweden solely because the income is also income derived by a resident of Sweden (BEPS provision);
  • The replacement of Article 25 (Exchange of Information) in line with OECD standards on information exchange; and
  • The amendment of Article 27 (Limitations of Benefits) with the addition of the provision that a benefit under the treaty will not be granted in respect of an item of income if it is reasonable to conclude, having regard to all relevant facts and circumstances, that obtaining that benefit was one of the principal purposes of any arrangement or transaction that resulted directly or indirectly in that benefit, unless it is established that granting that benefit would be in accordance with the object and purpose of the relevant provisions of the treaty.

The protocol will enter into force 30 days after the ratification instruments are exchanged and will generally apply from 1 January of the year following its entry into force.

Powerful Tax Tools


FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.


Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.


Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.


Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.


Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.



Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.


Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.


Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.


Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.


Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.


Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.


Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.


VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.


NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.


Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.


Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

FX Rates

Global FX Rates including Tax year Average FX Rates and Spot Rates for all Reporting Currencies.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More