Double Taxation Agreement Switzerland Portugal

Over the years, Portugal has signed fifty-two double taxation treaties for the avoidance of double taxation of income tax under the OECD Model Convention, with certain reservations aimed primarily at ensuring a more comprehensive design of permanent establishment and raising the level of taxation in the country of origin with regard to dividends, interest and royalties. In concluded contracts, the ordinary tax credit method is generally used, but it should be noted that in some contracts, a corresponding credit note or tax saving credit note is provided. Portuguese residents are subject to the taxation of their worldwide income at progressive marginal tax rates, and certain types of income are taxed at flat rates (between 10 and 28 per cent), and non-residents are subject to Portuguese tax on their Portuguese income at the applicable rates (between 10 and 28 per cent), depending on the type of income received. A double taxation convention may provide for a derogation from these provisions. There is no minimum threshold/number of days that exempts the employee from the obligation to file and pay taxes in Portugal with respect to Portuguese working days. However, the application of a double taxation agreement may establish that the worker is not obliged to register, provided that the person spends less than 183 days in Portugal and that the person`s income is not paid by a Portuguese company or credited to a Portuguese company. Discover our interactive map of double taxation agreements between Switzerland and the contracting countries. www.bundesfinanzministerium.de/Content/EN/Standardartikel/Topics/Taxation/Articles/double-taxation.html www.porezna-uprava.hr/en/EN_porezni_sustav/Pages/double_taxation.aspx is usually when two states tax the same income or assets of a taxpayer. Most of the provisions of a DTA are aimed at avoiding double taxation by giving States parties the right to tax each type of income and asset. However, they merely restrict the right of taxation of the Contracting States.

The taxable amount shall be the domestic law of the Contracting States. www.revenue.ie/en/tax-professionals/tax-agreements/double-taxation-treaties/tax-treaties-by-country.aspx?page=R Most contracts generally follow the OECD Model Treaty. Double taxation is generally avoided by applying the "progression exemption" method, i.e. all income is taken into account in determining the applicable tax rate, but no tax is actually levied on the exempt income. Uncollectible foreign taxes on capital gains (interest, dividends) are generally deducted up to the respective actual Swiss tax on such income. Unused appropriations may not be carried over. www.mfsr.sk/en/taxes-customs-accounting/direct-taxes/income-tax/international-taxation/double-tax-treaties/ 30.07.2019 Entry into force of the new double taxation agreement between Switzerland and Zambia www.government.is/topics/economic-affairs-and-public-finances/tax-treaties/double-taxation-treaties/#panel-7a79c16a-d05d-11e7-941f-005056bc4d74-29 26.08.2020 The Federal Council adopts the dispatches on the new double taxation agreement double taxation with Bahrain and amends them from the DTA with Kuwait Taxes on income and wealth levied in countries with which Switzerland has not concluded a DVB-T cannot be deducted from Swiss taxes, nor are the underlying income or assets exempt from Swiss tax. However, the taxpayer may claim a deduction of input tax from the amount of non-refundable foreign taxes. 28.10.2019 Amendments to the double taxation agreement with the United Kingdom in force In order for the amendments introduced by the BEPS Convention to take effect, Switzerland must also notify the DEPOSITARY of the BEPS Convention that the necessary procedures have been completed.

The first such case concerned Luxembourg. In a Memorandum of Understanding of 12 May 2020, the competent authorities of Switzerland and Luxembourg adopted the exact wording of the amendments provided for in the BEPS Agreement (see AS 2020 2641 and AS 2020 2715). The procedure has thus been completed and Switzerland has sent the above-mentioned notification to the depositary of the BEPS Convention. These changes are reflected in the double taxation agreement between Switzerland and Luxembourg. Switzerland intends to align DTAs not modified by the BEPS Agreement with beps minimum standards through bilateral amendments to DTAs. .