They say the devil is in the detail and this applies this year as some items may appear innocuous but if you study the knock-on effect they need to be considered seriously.
There was talk pre year end of Delaware being blacklisted by the EU and penalty taxes being applied on non-resident property companies where the directors were located in blacklisted jurisdictions. The first never came to pass and we are holding our breath on the latter!
The devil, however, was the implementation, late November, of the Register of Effective Beneficial Ownership (REBO). What REBO means is that any company, foreign or otherwise, that has a Fiscal Number (NIF) in Portugal will now have to declare who is the beneficial owner of its shares or the right to those shares.
Revelation of their beneficial ownership should not be a problem for genuine people but the real impact of the REBO is that it will now be straightforward to see when John Smith transfers the shares of his property company to Peter White as the REBO will have to be updated. Will that give the Tax Department an opportunity to pry into the transaction and tax it based on some presumption of a profit made?
Furthermore if we link that piece of legislation to the change in the Budget, which says that transfers of shares of any company that owns 50% or more of a property in Portugal will be taxable EVEN if the shares are held by non-residents of Portugal, you can see the way things are going perhaps?
The days of tax avoidance by simple concealment are long gone and the future is self-declaration of all types of income, in your country of residence, wherever they may arise.
It would be good if that Revenue was used for the good of the country so perhaps that is the next phase we can look forward to?
Contact sovereign - Consultoria Lda for more information on corporate ownership, fiscal representation or other fiscal matters relating to property ownership in Portugal.

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Tel: (+351) 282340480
or email: port@sovereignGroup.com