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The non habitual resident regime turns Portugal a European Union white listed friendly tax environment. Portugal has a long established optional Personal Income Tax (PIT) regime for the so called non habitual residents, offering very special PIT incentives, thus attracting to Portugal talent in high value added activities, as well as the Ultra and High Net Worth Individuals (UHNWI’s) and their families. All individuals (Portuguese or not) becoming tax resident in Portugal, can opt for such regime (granted for a period of 10 consecutive years), provided they were not Portuguese tax residents in the previous 5 years. Non habitual residents are subject to a reduced flat 20% PIT rate, both on salaries and business and professional income of a Portuguese source arising from listed high added value activities Non habitual residents are also PIT exempt on salaries of a non Portuguese source, provided such income is subject to tax in the source country following an existing Double Tax Treaty or if the same is subject to tax in the other jurisdiction and is not considered as Portuguese source income under domestic rules, tin he absence of such Tax Treaty. Non habitual residents business and professional income of a non Portuguese source, relating to listed high added value activities, intellectual or industrial property or also industrial, commercial or scientific information, is PIT exempt if it could have been taxed in the source country under an existing Double Tax Treaty or could have been taxed in another non black listed jurisdiction in accordance with the OECD Guidelines (Model Treaty). Subject to actual taxation at source pensions paid abroad to non habitual residents are also PIT exempt. To enhance the regime stability and compliance to international standards, the Budget Act for 2020 introduced a new 10% flat tax rate to qualifying pensions not actually taxed at the source country. Although such new taxation is only applicable to new non habitual residents, those already benefiting from an existing 10 years period may opt for such 10% tax (thus securing non taxation at source). Qualifying pensions should have been tax at source or should not be due by Portuguese residents, should not relate to contributions done in Portugal or that allowed for a PIT deduction in Portugal. Some other income (rental income, investment income and capital gains) of a non Portuguese source obtained by non habitual residents are also PIT exempt, provided it could have been taxed under an existing Double Tax Treaty or could have been taxed in another non black listed jurisdiction in accordance with the OECD Guidelines (Model Treaty). In short, the non habitual resident regime allows professionals and UHNWI’s to accrue their income and wealth in a white listed friendly tax environment. Due to the main rules of the Portuguese general system they are also able to sell or to dispose of their assets benefiting from generous tax exemptions or exclusions (including income, wealth and inheritance or gift taxes). Foir such reasons also family offices and multinational companies are increasingly opting for Portugal as a basis for their operations and activities. Find out how this regime could be combined with the so called Golden Visa (Portuguese by investment residency program) leading to outstanding opportunities in Europe's west coast. April 2020 update For generic information purposes only Specific advise must be obtained before any decision is taken

Madeira special tax regime: an European instrument not to be missed by MNC’s, entrepreneurs and their advisors. Madeira IBC offers relevant tax benefits, in a white listed environment fully integrated in the European Union (and Portuguese) legal system, that can be further combined with other general and special Portuguese tax incentives. Madeira is a Portuguese island located in the middle of the Atlantic Ocean, close to Europe’s southwest coast and Africa’s northwest coast. Madeira International Business Centre (MIBC) offers a white listed, totally transparent, not ring fenced and fully European Union (EU) compliant special taxation regime. The regime is very simple, pragmatic and effective. Furthermore, investors can also apply for general incentives (tax benefits, subsidies and grants), including the so called non habitual resident and golden visa regimes (such combination of regimes is a true option and thus not required and often not even advisable). As the regime is transparent and not ring-fenced, Portuguese tax residents (individuals and corporations) can also benefit from the MIBC regime and Portuguese and EU regulations do apply. Under MIBC tax framework corporations (and their investors) can benefit from a number of relevant EU approved tax benefits, including: 5% corporate income tax rates on almost all international activities (for royalties a 2,5% tax rate can be possible), subject to thresholds of reasonable substance requirements and job creation; Withholding tax exemptions; Stamp Duty, Property Tax and Property Transfer Tax exemptions. Not being a ring fenced regime, the main advantages of the Portuguese laws and regulations do apply, including: Participation exemption for paid and received dividends and capital gains; Optional territorial regime for permanent establishments abroad; EU Directives (dividends, interest & royalties, mergers); Tax incentives for job creation, investment, retention and reinvestment of profits, equity (notional interest deduction) and R&D (e.g. patent box, special tax depreciation for certain intangibles without limited useful life), venture capital, etc; Double tax treaty network; No wealth tax; Virtually no inheritance and gift tax; Double tax treaties and Social security and Investment protection agreements, together with very special links to the remaining Portuguese Speaking Countries (CPLP) and very convenient flights, turns Portugal an ideal investment hub, notably for the South Atlantic area. Substance requirements Creation of 1 to 5 jobs in the first six months of activity, together with a minimum total CAPEX of EUR 75 000 during the first two years of activity. Alternatively, creation of a minimum of 6 jobs during the first six months of activity. Additionally, the following thresholds and job creation requirements apply (thus taxable income in excess is subject to the the standard tax rate and not the the reduced 5% nominal tax rate): 2.7 millions euro / 1-2 jobs; 3.5 millions euro / 3-5 jobs; 21.8 millions euro / 11-50 jobs; 35,5 millions euro / 36-30 jobs; 54 millions euro /51-100 jobs; 205 millions euro / More than 100 jobs; Capped at one of the 3 following limits: a) 20,1% of gross value added; b) 30,1% of annually incurred labor costs; c) 15,1% of the annual turnover. Do you know the Madeira Business Center incentives are also available to non habitual residents? April 2020 update For generic information purposes only Specific advise must be obtained before any decision is taken

Portugal is a key investment and relocation jurisdiction, offering excellent lifestyle and investment opportunities, with very relevant tax benefits. Professionals, entrepreneurs, family business and MNC’s should consider Portugal, notably for innovation, venture capital and as an hub for the South Atlantic Ocean. Portugal is part of the European Union, the Euro Zone and the Schengen area. The country enjoys an outstanding quality of life in a safe multicultural environment, with a stable political system and easily available highly skilled and English fluent professionals. The legal and tax regime for individuals and companies is very attractive, surpassing by far other comparable regimes. Furthermore, Portugal offers a very low and competitive effective tax burden, either for individuals (non habitual resident regime) and corporations (Madeira International Business Center), a number of extremely relevant tax incentives and grants and an effective double tax treaty network and relevant international agreements (such as investment protection and social security). Also due to its traditional liberalism and multicultural approach, Portugal is additionally a very effective hub to Portuguese Speaking Countries and the economic regions of wish such countries are members. Thus, Portugal still offers an extremely favorable investment climate continuing its clear strategy of remaining a hotspot location for R&D and digital disruption, premium tourism and real estate investment. For non European Union individuals and their families, on top of a favorable tax regime, Portugal also offers an effective residence by investment program (the so called Golden Visa regime), granting access to Schengen and possibly to citizenship. That’s why I consider Portugal the Europe’s best kept secret, notably for investment. April 2020 update For generic information purposes only Specific advise must be obtained before any decision is taken