NEWSLETTER I TAX CONTENTS TAX NEWSLETTER I 3RD QUARTER 2017 EDITORIAL
I BENEFICIAL OWNER CENTRAL REGISTRY: PROPORTIONAL? II SINGLE DIGITAL ADDRESS AND TAXPAYERS' NOTIFICATIONS
III NATIONAL LEGISLATION
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NEWSLETTER I TAX I 1/14
It is with great pleasure that I introduce to you the new format of the Tax Newsletter of Cuatrecasas, Gonalves Pereira: a more focused approach, to be issued on a quarterly basis, leaving behind the traditional descriptive presentation of legislation, doctrine and jurisprudence, and seeking to focus our (and your) attention on the most relevant aspects that affect the legal-tax practice of the Portuguese market.
The third quarter of 2017, contrarily to the apathy that traditionally characterizes the so called silly season, was remarkable for the taxation field.
At the international level, the 71st Congress of the International Fiscal Association (IFA) in Rio de Janeiro was a milestone, with approximately 2,000 participants, a remarkable figure that made this event the second largest congress outside Europe in the history of IFA. Following the most recent OECD trends, the two mains topics concerned the implementation of the various actions of the BEPS Plan (Base Erosion and Profit Shifting) and the future of transfer pricing.
Aimed at combating the erosion of the tax base and the transfer of pro fits to low-tax jurisdictions, the BEPS Plan has been the main focus of attention for tax administrations, consultants, lawyers and multinational groups. Thus, Rio de Janeiro has provided an excellent opportunity to publicise the developments at worldwide level, with regard to the implementation of its 15 actions, emphasizing the impact of this ambitious project for the European Member States and their relations with third countries. Surely, coherence, substance and transparency are the key concepts to discuss, and will likely continue to be discussed in the future.
The future of transfer pricing, intrinsically related to the BEPS Plan but still having its autonomy, was the focus of attention for multinational groups and of their advisers. Aiming at having a fair allocation of taxing powers in a cross-border context, the future of transfer pricing brought together experts from around the world to discuss the fundamentals and difficulties of applying the various regimes worldwide, the most recent developments, and debating potential dispute resolution mechanisms. The cornerstone of the discussion related to the huge costs faced by multinational groups in the implementation of OECD standards on transfer pricing, as well as the (still) significant legal uncertainty that the current regimes and international mechanisms enhance. Only one certainty exists: in today's world the issue of transfer pricing is - and will be increasingly - one of the main focuses of attention for tax administrations and taxpayers.
At a purely national level, the summer of 2017 was also remarkable, considering measures for pursuing the aims of combating cross-border tax evasion and tax avoidance.
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In this context, we highlight the approval of the legal provisions that impose the annual publication by the Portuguese Tax and Customs Authority of information on transfers and remittances, the updating of the list of jurisdictions participating in the automatic exchange of information mechanism for financial accounts, the obligation of using specif ic means of payment for transactions involving amounts equal to or greater than EUR 3,000, the changes in the conditions for the qualification of a country, region or territory as a low -tax jurisdiction and the regulation of the mandatory automatic exchange of information on cross-border tax rulings and advance pricing agreements.
Among the various Laws approved between July and September 2017, we highlight the creation of the single digital address and its impact on taxpayers' notifications, as well as the Laws approved in relation to the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, whose importance in tax matters has been relatively unnoticed. Having efficiency as their common aim, these Laws impose significant administrative burden and structure costs on Portuguese taxpayers, whereby its reasonableness and proportionality are questionable. The importance of these two topics justifies a more in-depth analysis, which we start today through the two articles of this Newsletter.
We also welcome two long expected measures: the recognition of the right of jointly declaring for personal income tax (PIT) purposes income and expenses related to dependents where parental responsibilities are exercised by more than one taxpayer; and the obligation by the Portuguese Tax and Customs Authority of collecting and publishing all the issued and future binding rulings. While the first measure will only produce its effects in 2018, the second has already lead to plenty of publications on the views of the Portuguese Tax and Customs Authority, which will certainly contribute to greater legal security and certainty in its relationship with Portuguese taxpayers.
The next issue of this Newsletter also promises: among macroeconomic forecasts and the already announced budgetary changes in tax matters, in particular following the submission of the 2018 State Budget Proposal to the Portuguese Parliament last October 13, surely interesting issues will arise: those will be covered in the next edition of our Newsletters.
Diogo Ortigo Ramos
NEWSLETTER I TAX I 3/14
I BENEFICIAL OWNER CENTRAL REGISTRY: PROPORTIONAL?
Within the context of transposing Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on prevention of the use of the financial system for the purposes of money laundering or terrorist financing, two Laws were recently approved: Law no. 83/2017, of 18 August, which establishes the preventive and repressive measures to combat money laundering and terrorism financing, and Law no. 89/2017, of 21 August, approving the Legal Regime of the Beneficial Owner Central Registry ("BOCR"), in compliance with article 34 of Law no. 83/2017, of 18 August.
In line with the complexity of the topics covered, the aforementioned Laws are extensive, legally complex, appeal to Anglo-Saxon concepts without direct parallels in RomanGermanic based systems (as the Portuguese one), being foreseeable that, once in force, difficulties will raise with regard to their application.
Construed by reference to the concept of beneficial owner as defined in Law no. 83/2017, of 18 August, the BOCR establishes, inter alia, the obligation for all Portuguese commercial companies to identify the natural persons who, even indirectly or through a third party, hold their corporate stakes or, in any other way, hold their effective control. For these purposes, and as it results from Law no. 83/2017, of August 18, the share capital threshold or, where applicable, the effective control to consider is benchmarked at 25% (being such benchmark reduced to 5% for certain purposes, e.g. bank purposes).
The introduction of the BOCR in the Portuguese legal system, having a significant impact on corporate governance and essentially aimed at combating money laundering and terrorism financing, will also impact the tax field.
In fact, regarding the tax exemption on profits and reserves distributed to non-resident entities, Law no. 89/2017, of August 21, adds paragraph 9 to article 14 of the Corporate Income Tax Code ("CIRC"), disallowing the existing tax exemption (i) in the cases where the issuer does not comply with the ancillary obligations set forth in the BOCR, as well as (ii) in cases where the revealed beneficial owner(s) are resident or domiciled in a low tax jurisdiction, in the latter case when the Portuguese company does not demonstrate that the construction or series of constructions of the group of which it is part are of genuine character (and, consequently, not being intrinsically tax-driven).
Without neglecting the practical difficulties that Portuguese companies (and other target entities) will likely face for complying with the identification of all the group entities - of which they are "mere" investees, without being able to determine behaviors and require information from those who actually control them - from a tax point of view, the reversal of the burden of proof in cases where the beneficial owner is resident in a low -tax jurisdiction raises serious doubts as to the compatibility with Europe an Union law.
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In fact, recent case-law of the Court of Justice of the European Union (Judgment of 7 September 2017 in Case C-6/16), considered that the reversal of the burden of proof under which the obligation to demonstrate that the group structure, which a taxpayer was a subsidiary of, did not have as main purpose (or as one of the main purposes) benefitting from the so-called Parent-Subsidiary Directive, was imposed to the taxpayer is contrary to European Union law. In this case, the Court scrutinized the French provision according to which dividends distributed to an European Union company held by a third country company can only benefit from the Parent-Subsidiary Directive if the taxpayer demonstrates (and exempting the French tax authorities from such proof) that the existing corporate structure did not have as its main purpose (or as one of its main purposes) benefitting from the exemption provided for in the Parent-Subsidiary Directive. The Court concluded that such a provision is not proportional, thus breaching not only article 1 (2) of the Parent-Subsidiary Directive, but also article 49 of the Treaty on the Functioning of the European Union.
The parallelism with paragraph 9 of article 9 of the CIRC seems to be clear: the Portuguese legislator also goes beyond the necessary, determining the reversal of the burden of proof in cases where the beneficial owner is a resident in a low-tax jurisdiction. Is this reversal of the burden of proof in line with European Union law?
But the tax impact of the recently-approved Laws, in particular the BOCR, is even wider.
How will the BOCR be combined (and which overlaps it will raise) with the existing mechanisms for the exchange of financial and tax information? One could consider the Multilateral Competent Authority Agreement on the Automatic Exchange of Financial Information (MCAA), to which Portugal has already adhered, or the Foreign Account Tax Compliance Act (FATCA), entered into with the United States of America.
If we focus on the European Union, primary consideration is to be given to the existing mechanisms for regional administrative cooperation in the field of taxation: firstly, via automatic exchange of financial information (Council Directive 2014/107/EU of 9 December, transposed into Portuguese law by Decree-Law no. 64/2016, of 11 October) and to a certain extent correspondent to the MCAA and FATCA at a more global level , and secondly via automatic exchange of advance cross-border rulings and advance pricing agreements (Council Directive (EU) 2015/2376 of 8 December, transposed into Portuguese law by Law no. 98/2017, of 24 August).
Regarding the access to financial and tax information of multinational groups allowing an overview of financial and tax data on the various countries in which group s operate several instruments were approved, of which we highlight the Country-by-Country Reporting ("CbCR") both at the global level via the Multilateral Agreement between Competent Authorities for the Exchange of Country-by-Country Financial and Tax Information ("MCAA of CbCR") and at European level via the Council Directive (EU)
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2016/881 of 25 May, transposed into the Portuguese legal system by the abovementioned Law no. 98/2017, of 24 August.
Within the scope of the referred mechanisms for automatic exchange of information, either at a more global level (MCAA, MCAA of CbCR and FATCA) or at European level, the information covered is required from entities who legally, effectively and directly receive and control it, without having to incur in additional charges i.e., financial institutions and tax authorities being subsequently made available to the relevant tax authorities.
Is it realistic and proportional to require private information (including birthday and all the data included in the personal identification document) about the beneficial owner(s) from Portuguese entities that do not have the same type of access to this (extensive) information, imposing them a significant administrative burden and costs for accessing it? Moreover, when, in many cases, considering the number of entities in the (upstream) structure this information is immensely detached from the Portuguese entity?
Given that Portuguese tax authorities already have access to the information which is necessary to ascertain financial and tax risks, will it be necessary to impose additional obligations to Portuguese taxpayers? Is this additional burden justifiable if considering the aims of the BOCR vis--vis the outcome that can already be achieved via existing instruments?
And finally, is the extent of the required information on the beneficial owner reasonable, being this obligation only limited in extreme cases of threat to the individual, without interfering with his privacy? And how to prove such a threat?
Bearing in mind that the aims pursued by the various mechanisms for accessing financial and tax information are to prevent and reveal money laundering schemes, tax fraud and aggressive tax planning, one may question if the CRBO will effectively allow access to new and necessary information, which could not be accessed without this (new) regime. It does not seem the most reasonable, appropriate and/or proportionate way of accessing that information for complying with the intended aims, to impose taxpayers an obligation of collecting and sharing information from third parties, without having the legal means for obtaining it.
While its entry into force is still pending, the BOCR is already raising significant doubts. Time will help clarifying part of them, while surely it will raise new ones. For the time being, one thing seems to be certain: Portuguese taxpayers are faced with the imposition of a heavy(-ier) administrative burden, with the underlying administrative, human and financial costs...
Tnia de Almeida Ferreira
Rita Botelho Moniz
NEWSLETTER I TAX I 6/14
II SINGLE DIGITAL ADDRESS AND TAXPAYERS' NOTIFICATIONS
Decree-Law no. 93/2017 was published on August 1, 2017, creating the "Single Digital Address" and the "Public Electronic Notifications Service" and setting-out the terms and conditions of electronic notifications made by public entities, including notifications made by the Tax Authorities.
The amendments introduced by Decree-Law no. 93/2017, of August 1, regarding electronic notifications are the Government's most recent step aiming at simplifying and computerising communications between the Tax Authorities and taxpayers.
In this respect, mention should be made to the fact that, since Law no. 64-B/2011, of December 30 2011 (2012 State Budget Law), taxpayers may subscribe to an "Electronic Postal Box" ("ViaCTT" Service), which supplements the traditional postal box meant for paper mail and enables the centralised reception of digital mail. According to article 19(10) of the General Tax Law, the subscription of the Electronic Postal Box is compulsory to all taxpayers subject to Corporate Income Tax or bounded or to the normal Value -Added Tax regime.
Unlike the Electronic Postal Box, the newly created Single Digital Address is an e -mail address voluntarily appointed by the taxpayers that formally becomes part of their tax domicile and to which all notifications made by Public Administration Servi ces that adhere to the Public Electronic Notifications Service will be sent.
It seems that such Public Electronic Notifications Service which is supposed to be up and running until the end of the current year will coexist with the existing Electronic Postal Box service. In other words, the subscription of the Single Digital Address is optional to all taxpayers but does not exclude the obligation to subscribe to the Electronic Postal Box when such subscription is mandatory.
Furthermore, Decree-Law no. 93/2017, of August 1, also amends the Tax Procedural Code in what concerns electronic notifications, regardless of these being made via Single Digital Address or via Electronic Postal Box, namely determining when taxpayers are considered to be validly notified.
In light of the above, it is worth revisiting the legal framework applicable to the notification of taxpayers by the Tax Authorities, focusing in particular on the electronic notification regime.
As per article 36 of the Tax Procedural Code, tax acts that impact on rights or lawful interests of taxpayers only become effective upon the corresponding valid notification to the affected party. The existence of a valid notification is a condition of the effectiveness of the notified act. It is therefore of great importance for taxpayers to understand how and when they can be notified.
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Traditionally, most notifications made by the Tax Authorities are effected via registered mail, which must be sent with acknowledgement of receipt in case the act being notified is one that may alter the tax position of taxpayers or one destined to summon them to take part in proceedings.
When a notification is effected via registered mail with acknowledgement of receipt, th e act it refers to is held as validly notified to the taxpayer on the date in which the receipt is signed. On the other hand, when a notification is effected via registered mail without acknowledgement of receipt, the corresponding act is presumed as validly notified on the third day after the day of remittance. In this last case, if applicable, the taxpayer is entitled to prove that the notification occurred after the third day. In other words, despite the existing presumption of notification, the purpose is nevertheless to ascertain when the taxpayer took knowledge of the act.
It is further legally established that all above-mentioned notifications, as well as notifications within tax foreclosure proceedings, may instead be effected via electronic means, in which case the transmission will be equivalent to the dispatch via registered mail or via registered mail with acknowledgement of receipt, as applicable to the specific case. Therefore, the Electronic Postal Box, when subscribed-to, is suitable to receive any kind of notification.
Concerning the timing when electronic notifications are considered to have occurred, up until the recently approved Decree-Law no. 93/2017, of August 1 2017, taxpayers notified via Electronic Postal Box were held as notified when they accessed the mail box or on the twenty-fifth day after the notification dispatch, whichever came first. In other words, to make sure knowledge of notifications sent by the Tax Authorities occurred on the date of notification, a taxpayer had the burden of accessing the Electronic Postal Box at least every 25 days.
With the entry into force of Decree-Law no. 93/2017, of August 1 2017, electronic notifications (by Electronic Postal Box or by Single Digital Address) are held as made on the fifth day after the corresponding electronic dispatch, regardless of the effective date of access by the taxpayers. This means that taxpayers who intend to timely take knowledge of notifications must now access their Electronic Postal Box or Single Digital Address at least every 5 days.
In spite of the legally foreseen possibility of taxpayers rebutting the presumption of notification on the fifth day by demonstrating that the notification occurred later due to a cause not attributable to them, it is difficult to anticipate exactly how will a taxpayer be able to prove it. For example, will it be accepted as an admissible justification the demonstration that the taxpayer was traveling, with no access to the Internet? May this situation be regarded as not attributable to the taxpayer? And, even if so, how can the taxpayer demonstrate such fact?
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All in all, even though subscription to the Single Digital Address and to the Public Electronic Notifications Service is voluntary and the dispatch of paper notifications to the taxpa yers' tax domicile is still permitted, the generalisation of electronic notifications is an undeniable trend. It is beyond doubt that this type of notification renders communication between Tax Authorities and taxpayers easier, more efficient and cost-effective, in addition to avoiding certain notification problems, namely due to errors or changes of the tax domicile. However, such gains should not be obtained at the taxpayers' expense. In this respect, special reference should be made to this unexpected and scarcely announced alteration of the presumption from 25 to 5 days, bearing in mind that a legal burden of permanent connection to the internet is being gradually implemented.
Nevertheless, at least until the situations in which the lack of access to the Electronic Postal Box or to the Single Digital Address within 5 days after the notification dispatch or arrival at the postal box is not attributable to the taxpayer are clarified, it is highly recommended that any taxpayer who, compulsorily or voluntarily, may be electronically notified accesses the corresponding postal box, at least once every 5 days. That is the only way to avoid being held as legally notified of something despite not actually taking knowledge of it.
Pedro Vidal Matos
Iara Marques Freitas
III NATIONAL LEGISLATION
Ministry of Foreign Affairs Notice no. 68/2017, of 26 June, published in July 2017
Making known that the Embassy of Portugal and the Socialist Republic of Vietnam have complied with the internal constitutional formalities for the approval of the Convention between the Portuguese Republic and the Socialist Republic of Vietnam to Avoid Double Taxation and Prevent Tax Evasion with respect to Taxes on Income.
Ministry of Foreign Affairs Notice no. 70/2017, de 27 June, published in July 2017
Making known that a note verbale was received from the Embassy of India in Lisbon, announcing the intention of the Government of the Republic of India to terminate the Agreement between the Portuguese Republic and the Republic of India on the Promotion and Reciprocal Protection of Investments, thus ceasing its application on 5 May 2017.
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Ministry of Foreign Affairs Notice no. 71/2017, of 28 June, published in July 2017
Making known that the Embassy of Portugal and the Kingdom of Bahrain have complied with the internal constitutional formalities for the approval of the Convention between the Portuguese Republic and the Kingdom of Bahrain to Avoid Double Taxation and Prevent Tax Evasion with respect to Taxes on Income.
Ministry of Foreign Affairs Notice no. 80/2017, of 28 June, published in July 2017
Making known that the Embassy of Portugal and the Sultanate of Oman have complied with the internal constitutional formalities for the approval of the Convention between the Portuguese Republic and the Sultanate of Oman to Avoid Double Taxation and Prevent Tax Evasion with respect to Taxes on Income.
Presidency of the Council of Ministers Declaration of Rectification no. 445/2017, of 16 June, published in July 2017
Rectifies Ordinance no. 89-A / 2017, of 19 April, which approved the regulation of the Tax Incentive for Cinematographic Production, foreseen in article 59-F of the Tax Benefits Law ("EBF").
Ministry of Finance and Ministry of Planning and Infrastructures Ordinance no. 208/2017, of 13 July
Regulates article 41-B (4) of EBF, regarding the tax benefits applicable to the establishment of companies in the interior territories, approved in an annex to Decree-Law no. 215 / 89, of 1 July, defining the territorial areas capable of benefiting from the measures of the National Program for Territorial Cohesion, for the purposes of developing the interior territories.
Ministry of Finance Ordinance no. 215/2017, of 20 July
Regulates the procedure and the term for the exercise of the payment option of Value Added Tax ("VAT") due on the import of goods through the periodic declaration as foreseen in article 27 (8) of the VAT Code.
Ministry of the Presidency and Administrative Modernization Decree-Law no. 93/2017, of 1 August
Creates the single digital address and related public electronic notification service, and regulates the terms and conditions for sending and receiving electronic notices.
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Office of the Secretary of State for Fiscal Affairs Normative Order no. 7/2017, of 8 August
Amends Normative Order no. 18-A/2010, of 1 July, which amends the instructions for filling the Suppliers' List and the Customers' List, required within the context of the VAT refund application foreseen in article 41 of the VAT Code.
Parliament Law no. 69/2017, of 11 August
Regulates the credit recovery funds, making reference in its article 70 to the applicable tax regime.
Ministry of Finance Ordinance no. 256/2017, of 14 August
Determines the annual publication by the Portuguese Tax Authorities of the information on transfers of funds, referred to in article 63-A (3) of the General Tax Law ("LGT"), and of the information on transfers of funds to be included in the detailed report on developments on countering of tax avoidance and tax evasion, in accordance with article 64-B of the LGT.
Ministry of Finance Ordinance no. 255/2017, of 14 August
Reviews Ordinance no. 302-D/2016, of 2 December, updating the list of participating jurisdictions referred to in paragraph 6 of article 2 of Decree-Law no. 64/2016 of 11 October.
Parliament Law no. 75/2017, of 17 August
Establishes the tax regime and exemption from court fees of common land and other collective means of production owned and managed by local communities integrated in the cooperative and social sector of the means of production, referred to in article 82 (4) (b) of the Constitution of the Portuguese Republic ("CRP").
Parliament Law no. 85/2017, of 18 August
Amends Decree-Law no. 41/2016, of 1 August, and the Property Tax ("IMI") Code, approved as an annex to Decree-Law no. 287/2003 of 12 November, and extends the validity of the tax benefits related to scientific patronage until 31 December 2017.
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Parliament Law no. 89/2017, of 21 August
Transposes Chapter III of Directive 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorism financing, and approves the Legal Regime of the Beneficial Owner Central Registry ("RCBE"), foresee in article 34 of Law no. 83/2017, of 18 August.
Parliament Law no. 92/2017, of 22 August
Imposes the use of specific means of payment for transactions involving amounts equal to or higher than EUR 3,000, amending article 129 of the General Regime of Tax Infringements ("RGIT") and the LGT.
Parliament Law no. 91/2017, of 22 August
Modifies the conditions under which a country, region or territory can be considered as a low tax jurisdiction by amending article 63 (1) and (2) of the LGT.
Presidency of the Republic Law no. 98/2017, of 24 August
Regulates the mandatory automatic exchange of information on cross-border binding rulings, advance pricing agreements and on taxation, transposing Council Directives (EU) 2015/2376, of 8 December 2015, and (EU) 2016/881 of the Council, of 25 May 2016.
Ministry of Foreign Affairs Notice no. 108/2017, of 1 September
Making known that the Ministry of Foreign Affairs of Cte d'Ivoire and the Ministry of Foreign Affairs of Portugal have informed on the compliance with the domestic law requirements for the entry into force of the Convention between the Portuguese Republic and the Republic of Cte d'Ivoire for the Avoidance of Double Taxation and the Prevention of Tax Evasion with respect to Taxes on Income.
Ministry of Foreign Affairs Notice no. 109/2017, of 1 September
Making known that the Ministry of Foreign Affairs of Sao Tome and Principe and the Ministry of Foreign Affairs of Portugal have informed on the compliance of the domestic law requirements for the entry into force of the Convention between the Portuguese Republic and the Republic of Sao Tome and Principe for the Avoidance of Double Taxation and the Prevention of Tax Evasion with respect to Taxes on Income.
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Ministry of Finance Decree-Law no. 113/2017, of 7 September
Merges the Customs Stabilization Fund (FEA) into the Tax Stabilization Fund (FET).
Presidency of the Council of Ministers Declaration of Rectification no. 573-A/2017, of 4 September
Amends Normative Order no. 7/2017, which amended the instructions for filling the Suppliers' List and the Customers' List required for the VAT refund application foreseen in article 41 of the VAT Code.
Parliament Law no. 106/2017, of 4 September
Amends the Personal Income Tax ("IRS") Code, ensuring the right to submit a joint declaration of expenses and income relating to dependents in situations where the parental responsibilities are exercised by more than one taxpayer.
Ministry of Finance Order no. 7689/2017, 12 July, published in September 2017
Determines the Tax and Customs Authority to identify unpublished binding rulings in order to expedite its publication, to publish all the future binding rulings to be issued, and to annually publish the IRS assessment rules.
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