Oportunidades de poupança fiscal para empresas estrangeiras
| Autor | Franco Caiado Guerreiro & Associados |
O Acordo para evitar a Dupla Tributação assinado entre Portugal e vários outros países, como a Áustria, Alemanha, Finlândia, Suiça, ou Reino Unido, prevê uma "cláusula de crédito de imposto fictício", a qual poderá ser fiscalmente interessante ao nível das operações financeiras ou operações intra-grupos. De acordo com esta cláusula, pode ser concedido um crédito no Estado da residência tendo em conta o imposto que devia ter sido pago em Portugal, não fosse o caso de existirem benefícios fiscais. A título de exemplo, no caso de uma empresa alemã celebrar um contrato de empréstimo com uma...
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