Portugal: New tax treaties with Hong Kong and the UAE
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Double taxation treaties (DTTs) between the following markets were signed and came into force with the rates as indicated:
| Markets | Date signed | Date in force | Max DTT rate (%) | |
| Debt | Equities | |||
| Portugal - Hong Konga | 22 March 2011 | 3 June 2012 | 10 | 10 |
| Portugal - United Arab Emiratesb | 17 January 2011 | 22 May 2012 | 10 | 15 |
a. This treaty generally applies in Portugal from 1 January 2013 and in Hong Kong from 1 April 2013.
b. This treaty generally applies from 21 June 2012 concerning the withholding tax.
Important note:
Hong Kong and the United Arab Emirates are currently listed as tax havens by the Portuguese Tax Authorities, as published in Diário da República n° 214 (see also our Announcement A11172, dated 10 November 2011) and their residents are, therefore, not eligible to hold Portuguese domestic bonds with Clearstream Banking (according to art.17 of DL 193/2005).
With regard to the implementation dates mentioned above, residents of Hong Kong and the United Arab Emirates can hold Portuguese equities and, provided that the required certification is submitted, they could benefit from the respective DTT rate. If such documentation is not submitted, beneficial owners of Portuguese equities from these countries will be taxed at 30% (the rate for residents of tax havens).