There is a special group tax regime. A group may be formed by a parent and its fully-owned (90% or more, directly or indirectly) subsidiaries, provided that such ownership confers on the parent more than 50% of the voting rights and is maintained by the parent for more than one year prior to the application of the special regime.

The following income is considered to be Portuguese source income:

• Income relating to immovable property located in Portuguese territory, including gains on the transfer of such property for consideration;
• Gains arising from the onerous transfer of participations in resident Portuguese entities, including their redemption and amortization in a capital reduction, as well as the value assigned to members as a result of a division that is deemed to be capital gains, or other securities issued by entities that have their legal seat or their place of effective management in Portugal, or from shares or other securities, not meeting these conditions, where the income payment is attributable to a PE situated in Portugal;
• Income mentioned below where the debtor is a Portuguese resident entity, or the relevant payment is attributable to a PE situated therein:
  • intellectual or industrial property income as well as the supply of information relating to an experience in the industrial, commercial or scientific sector income;
  • the use or granting the right to use of agricultural, industrial, commercial or scientific equipment income;
  • other capital income;
  • remuneration of members of statutory bodies of legal persons and other entities;
  • prizes from gambling, lotteries, raffles and betting as well as prizes in any sweepstakes or contests;
  • intermediation in the execution of any income agreements;
  • income resulting from other services performed or used in Portugal, except those relating to transport, communications and financial activities;
  • the income resulting from transactions relating to derivative financial instruments;
• Income resulting from the activities carried out in Portugal by professional entertainers or professional athletes.
• Positive variations in equity from free acquisitions referring to:
  • rights in rem on immovable property situated in Portugal;
  • movables registered or subject to registration in Portugal;
  • participation in the capital of an entity and other securities issued by a Portuguese resident entity;
  • industrial property rights, copyrights and other related rights, registered or subject to registration, in Portugal;
  • credit rights on Portuguese resident entities;
  • participation in the capital of non-resident companies whose assets are mainly formed by rights in rem on immovable property situated therein.

Under specific circumstances, income referred to in c) above shall not be considered to be obtained within the Portuguese territory.