The central tax issues that foreign enterprises may encounter when doing business in Portugal are:

• the tax burden on enterprises who wish to invest in Portugal is high and may become higher considering the financial and economic crisis;
• Portuguese tax law is very complex and susceptible to several interpretations, hence the taxpayers’ interpretation of a specific provision may not coincide with the tax authorities’ or courts’ interpretation;
• the Portuguese tax authorities are now resorting to the application of the GAAR, and specific anti-avoidance rules, where there is little case law. justice is not prompt; procedures may be pending in court for a number of years.