Portugal

November 2024

Pillar Two - Portugal adopts the Global Minimum Tax

Law 41/2024, of 8 November, published in the Official Gazette, transposes into national legislation Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups whose annual consolidated revenue is equal to or greater than 750 million euros (Pillar Two Directive). 

This new regime, formally designated as the Global Minimum Tax Regime (“Regime do Imposto Mínimo Global” or “RIMG”), follows the model rules developed by the OECD/G20 Inclusive Framework. It introduces a new top-up tax when the effective tax rate of a covered group, in any of its jurisdictions, calculated according to the newly approved rules, is less than 15%.

For more details, read PwC Portugal's Tax Flash.

October 2024

2025 State Budget Law Proposal Submitted to Parliament

On 10 October 2024, the government submitted the 2025 State Budget Law Proposal to Parliament. For a detailed analysis of the main tax measures being proposed, please download the PwC Portugal Newsletter.

Corporate income tax (CIT)

• The standard CIT rate is proposed to be reduced by 1 percentage point, bringing it down to 20%.
• Small- and medium-sized enterprises (SMEs) and small mid-caps will be subject to a CIT rate of 16% (currently 17%) on the first 50,000 euros (EUR) of taxable income.

Tax incentives

• Incentive to the Capitalisation of Companies (ICE): ICE will be calculated by applying the average 12-month Euribor rate plus a spread of 2 percentage points, regardless of the company's size. The incentive rate will be increased by 50% (currently 30%). For more details about the ICE, see the Tax credits and incentives section.
• Proposed extension until 31 December 2025 of the following tax benefits provided in the Tax Benefits Code:
• Deductions related to partnerships of titles with social impact.
• Tax incentives for forestry activities.
• Tax incentives for forest management entities and forest management units.
• Tax incentives for electrosolar or exclusively electric vessels.

Extraordinary levies

• The following extraordinary levies will remain in force in 2025:
• Extraordinary levy on the energy sector (CESE).
• Bank levy.
• Solidarity surcharge for the banking sector.
• Pharmaceutical industry levy.
• Audiovisual levy: The monthly amounts are not updated.

September 2024

Repeal of the extraordinary contribution on local accommodation 

Decree-Law 57/2024, dated 10 September 2024, published in the Official Gazette, revokes the extraordinary contribution on local accommodation (CEAL). For more details, read the PwC Portugal Tax Flash.

August 2024

Real estate

Law No. 35/2024, published on 7 August 2024, authorises the government to revoke the extraordinary contribution on properties used for local accommodation and the ageing coefficient applicable to local accommodation establishments for the purposes of calculating the Real Estate Municipal Tax. In addition, there is the intention to eliminate tax obstacles to geographic mobility for work reasons. For more detail, read the PwC Portugal Tax Flash.

Value-added tax (VAT)

Law No. 38/2024, of 7 August 2024, published in the Official Gazette, provides for an extension of the application of the reduced VAT rate to the supply of electricity, applicable from 1 January 2025 onward. For more detail, read the PwC Portugal Tax Flash.

July 2024

Pillar Two - Law proposal under public consultation

On 11 July 2024, the government launched a public consultation for the law proposal approving the global minimum tax, transposing European Union (EU) Directive 2022/2523 (Pillar Two). 

The government proposes the transposition of Council Directive (EU) 2022/2523 of 15 December 2022 on ensuring a worldwide minimum level of taxation for multinational enterprise groups and large national groups within the Union, continuing the work of the Inclusive Framework on the Organisation for Economic Co-operation and Development (OECD)/G20 base erosion and profit shifting (BEPS) initiative, under Pillar Two, establishing common measures for the effective minimum taxation of these groups, creating for this purpose the global minimum tax (GMT) regime. 

For the sake of transparency, importance, and impact on society as a whole, it was understood that this proposal should be the subject of a broader discussion. Therefore, the government launched a public consultation so that there is an opportunity for broad participation by all sectors of civil society. The contributions received will, naturally, be taken into account in the final proposal to be submitted to the Parliament, so that the regime approved guarantees greater tax justice across the board for all taxpayers.

This consultation ends 31 July 2024.

Madeira Autonomous Region - 2024 Regional budget published

Regional Legislative Decree 6/2024/M, of 29 July 2024, approves the 2024 Budget for the Autonomous Region of Madeira. For more detail, read the PwC Portugal Tax Flash.

December 2023

2024 State Budget Law published

Law 82/2023, of 29 December 2023, approves the 2024 State Budget Law. Download PwC Portugal’s analysis for details.