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A company asks whether dividends and positive capital gains from the sale of shares in a closed collective investment society (SIC) in Portugal may qualify for corporate tax exemption. The DGT states that such exemption is possible if minimum holding periods, minimum shareholding thresholds, and foreign tax liability conditions are met.
Question raised
The positive income from the transfer of shares in the Portuguese SIC could benefit from the exemption under Article 21 of the LIS if the requirements of significant participation and holding period under letter a), and the requirement of being subject to a foreign tax of at least 10% under letter b) in each fiscal year of ownership, are met. Likewise, the exemption requires that the SIC does not have the status of a patrimonial entity and that the 5% reduction for management expenses is applied. Compliance with these requirements is a matter of fact that must be proven before the Administration.
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