SolvedDT15602 | Double Taxation Relief Manual: Portugal: treaty summary
From HM Revenue & Customs · Double Taxation Relief Manual
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Portugal are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on Portugal: tax treaties - GOV.UK
| Subject | Comments | Article |
|---|---|---|
| Portfolio dividends | 10% | 10 |
| Dividends on direct investments | 10% or 0% | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner must be a company which holds directly at least 10% of the capital of the company paying the dividends | 10 |
| Property income dividends | 15% | 10 |
| Interest | 10%/5%/0% | 11 |
| Conditions for 5% rate of interest | The beneficial owner must be a bank resident and regulated in the UK | 11 |
| Conditions for 0% rate on interest | The interest must be beneficially owned by the UK state, or one of it's politiacl or admisitrative subdivisions or local authorities | 11 |
| Royalties | 5% | 12 |
| Government pensions | Taxable only in Portugal unless the individual is a UK national | 18 |
| Other pensions | Taxable only in the UK | 17 |
| Arbitration | No | 24 |