The Portuguese tax treaty network covers more than 50 countries, including the US, Canada, UK, Japan, China, Hong-Kong, Singapore, Brazil, most of Western Europe, and most African countries belonging to the Community of Portuguese-Speaking Countries (Mozambique, Cape Verde, and Guinea-Bissau). The use of the Portuguese treaty network might allow a significant reduction of the applicable domestic withholding taxes.

Also, the special regime for debt securities (either public or private) enables non-residents to benefit from a tax exemption on interest payments and capital gains on the transfer of such securities (e.g., bonds, convertible bonds, repo loans) if such securities are integrated in a recognized centralized system. The exemption applies provided that the non-resident entity:

• Is not resident in Portugal and does not have a PE therein; is not a resident in a listed tax haven; and
• its share capital is not held, directly or indirectly, for more than 20% by Portuguese residents.