Cyprus has been removed from the so-called "blacklist"
published by the Portuguese tax authorities. Decree 150/2004 of the
Portuguese Ministry of Finance set out a list of more than 80
jurisdictions considered to have unduly favourable tax regimes.
Residents of countries on the list are denied certain benefits of
the Portuguese tax system, and subject to higher rates of certain
taxes. Companies resident in the countries on the list are subject
to the Portuguese CFC rules, with significant Portuguese
shareholders being liable to Portuguese tax on undistributed
profits attributable to them.
As Cyprus and Portugal are fully compliant with the relevant EU
Directives, particularly Directive 77/799/EEC concerning mutual
assistance by the competent authorities of the Member States of the
EU in the field of direct taxation and taxation of insurance
premiums and Directive 2008/55/EC on mutual assistance by the EU
Member States for the recovery of claims relating to certain
levies, duties, taxes and other measures, Cyprus has now been
removed from the list of "suspect" jurisdictions and
Cyprus-resident companies and individuals will no longer be subject
to unfavourable treatment.
Decree 292/2011 of the Portuguese Ministry of Finance, published
on 8 November 2011, sets out the revised "blacklist" of
81 jurisdictions, which include the Channel Islands, Gibraltar,
Hong Kong, the Isle of Man, Qatar, Seychelles and the British and
US Virgin Islands.
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