DT15602 - Double Taxation Relief Manual: Guidance by country: Portugal: Treaty summary

The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Portugal are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk .

Subject	Comments	Article
Portfolio dividends	15%	10
Dividends on direct investments	10%	10
Conditions for lower rate on dividends on direct investments	The beneficial owner must be a company which holds directly at least 25% of the capital of the company paying the dividends (Note 1)	10
Property income dividends	15%	10
Interest	10% (Note 1)	11
Royalties	5% (Note 1)	12
Government pensions	Taxable only in Portugal unless the individual is a UK national, without also being a Portuguese national	18
Other pensions	Taxable only in the UK (includes annuities)	17
Arbitration	No	N/A

Note 1: the recipient must be subject to tax in the UK on the same income.