General Shares Data

Reference information related to PHAROL listed stocks and contact information on relevant stock exchanges:​

According to the Bylaws of  PHAROL, SGPS S.A.​, share capital is represented by eight hundred ninety-six million, five hundred and twelve thousand, five hundred shares. 
As set on Article XIII paragraph 5 of the Bylaws, each share correspond to one vote.

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TAXATION OF DIVIDENDS AND OF CAPITAL GAINS

This information is of a general nature and does not apply to any entity or situation in particular. We cannot assure that the information is accurate at the date on which it is received / known or that it will remain identical in the future. No one should act according to this information without the appropriate professional advice for its specific situation.

TAXATION OF DIVIDENDS

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(a) The tax rate may be reduced under the provisions of a Double Tax Treaty (DTT) entered into between Portugal and the country in which the beneficiary of the income is resident.

(b) Under the Double Tax Treaty entered into between Portugal and Switzerland and depending on the participation held.

(c) Although the law provides for a specific regime in case of dividends distributed to Swiss investors, the possibility of benefiting from the withholding tax exemption under the regime applicable to investors resident in a country with whom Portugal has entered into between a DDT providing for administrative cooperation procedures in the field of taxation similar to those in force in the EU and subject and not exempt from CIT (or a similar tax), at a rate higher than 60% of the Portuguese general CIT rate [see note e) below] should be assessed on a case-by-case basis.

(d) Dividends placed at the disposal in bank omnibus accounts (except where the identity of the effective beneficiary is disclosed), are subject to withholding tax at a rate of 35%.

(e) The exemption only applies to entities resident in an European Economic Area Member State subject to administrative cooperation procedures in the field of taxation similar to those in force in the EU, or resident in a country with whom Portugal has entered into between a DDT providing for similar administrative cooperation procedures, provided, in both cases, that such entity is subject and not exempt from CIT (or a similar tax), at a rate higher than 60% of the Portuguese general CIT rate.

A) RESIDENTS

1. Individuals

Dividends paid to Portuguese resident individuals are subject to withholding tax at a rate of 28%. As a general rule, the tax withheld is deemed as the final tax due.

Notwithstanding, Portuguese resident individuals may elect to include the dividends in the income subject to the marginal Personal Income Tax rates. In this case, the withholding tax would have the nature of a payment on account for the final tax due.

In case a Portuguese resident individual makes such an election, only 50% of the total amount of the dividend will be considered for tax purposes.

If a Portuguese resident individual makes such an election, he would also have to include in the income subject to the marginal Personal Income Tax rates other income that, as a general rule, would only be subject to withholding tax (e.g. interest).

Dividends placed at the disposal in bank omnibus accounts (except where the identity of the effective beneficiary is disclosed), are subject to withholding tax at a rate of 35%.

2. Companies

Dividends paid to Portuguese resident companies are subject to a 25% withholding tax rate, which is considered as a payment on account for the final tax due.

Companies holding a direct or indirect participation of at least 5% for more than 12 months may benefit from a withholding tax exemption.

Dividends received must be included in the taxable profit of the company and would consequently be taxed at a rate of 23%, increased by a 3% state surcharge applicable to the taxable profit exceeding € 1,500,000, a 5% state surcharge applicable to the taxable profit between € 7,500,000 and € 35,000,000 and a 7% state surcharge applicable to the taxable profit exceeding € 35,000,000. The tax rate would also be increased by a municipal surcharge of up to 1.5%, depending on the municipality where the company is located.

Resident taxpayers with a commercial, industrial or agricultural activity as main business qualifying as a small or medium company under with Decree-Law no. 372/2007, of November 6, are subject to a corporate income tax rate of 17% on the first € 15.000 of taxable profit, and 21% on the remaining taxable profit. The reduced corporate income tax rate is subject to the minimum aid rules defined in the Commission Regulation n. 1998/2006, of December 15.

However, according to the Portuguese participation exemption regime, dividends may be exempt provided they derive from a direct or indirect participation of, at least, 5%, held for more than 24 months (or commitment to hold for such period).

Withholding tax on dividends will not be mandatory for entities which benefit from a Corporate Income Tax exemption, namely, pension funds, venture capital funds and Mutual Funds.

This exemption is not applicable, whenever these entities hold their participations for less than one year. In this case, dividends will be subject to an autonomous taxation, at a tax rate of 23%.

B) NON-RESIDENTS

Generally, dividends paid to non-resident individual investors, are subject to a 28% withholding tax rate. Dividends paid to non-resident corporate investors are subject to a 25% withholding tax rate.

In case the investor is resident in a country with whom Portugal has entered into between a DDT, the withholding tax rate may be partially reduced under the provisions set out therein.

Moreover, dividends paid to companies resident in an EU Member State, in an European Economic Area Member State subject to administrative cooperation procedures in the field of taxation similar to those in force in the EU or in a country with whom Portugal has entered into between a DDT providing for similar administrative cooperation procedures may benefit from a withholding tax exemption, provided the dividends derive from a direct or indirect participation of, at least, 5%, held for more than 24 months.

Furthermore, in case of dividends paid to companies resident in an European Economic Area Member State or in a country with whom Portugal has entered into between a DDT, the withholding tax exemption also depend on the company obtaining the dividends being subject and not exempt from CIT (or a similar tax) at a rate higher than 60% of the Portuguese general CIT rate.

This exemption may also be applicable to dividends paid to a Swiss company. In this case, the minimum holding percentage is 25% and the minimum holding period is two years. Although the law provides for a more restrictive regime in case of dividends distributed to Swiss investors, compared to the one applicable to investors resident in other countries with a DTT entered into with Portugal, we suggest you to seek for advice from your tax advisors as to the possibility of applying this latter regime as such possibility should be assessed on a case-by-case basis.

Dividends placed at the disposal in bank omnibus accounts (except where the identity of the effective beneficiary is disclosed), are subject to withholding tax at a rate of 35%.

The same withholding tax rate should apply to dividends paid to tax heaven entities.

TAXATION OF CAPITAL GAINS DERIVING FROM THE DISPOSAL OF SHARES

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(a) This exemption does not apply to individual or corporate investors resident in a tax heaven jurisdiction. Moreover, this exemption also does not apply to non-resident entities directly or indirectly held in more than 25% by Portuguese resident entities and when the assets of the company whose participation is disposed consist in real estate assets in more than 50%.
Nevertheless, in cases where the above-mentioned requirements are not met, capital gains may still be exempt under a relevant DTT entered into between Portugal.

(b) The applicable CIT rate is 21%, which is increased by a 3% state surcharge applicable to the taxable profit exceeding € 1,500,000,a 5% state surcharge applicable to the taxable profit between € 7.500.000 and € 35,000,000, and a 7% state surcharge applicable to the taxable profit exceeding € 35,000,000. In addition, the above-mentioned CIT rates may be increased by a municipal surcharge up to 1.5%, depending on the municipality where the company is located.​
Resident taxpayers qualifying as a small or medium company under with Decree-Law no. 372/2007, of November 6, are subject to a corporate income tax rate of 17% on the first € 15.000 of taxable profit, and 21% on the remaining taxable profit.

(c) This exemption only applies to taxable persons not covered by the tax transparency regime.

(d) According to paragraph 4 of article 72 of the Personal Income Tax Code, the 28% rate shall apply to the positive difference between capital gains and losses deriving from the disposal of shares.

A) RESIDENTS

1. Individuals

The positive difference between capital gains and losses deriving from the disposal of shares obtained by resident individuals in Portugal is subject to a 28% autonomous tax rate. However, the individual may opt to include the capital gain in the income subject to the marginal Personal Income Tax rates. If a Portuguese resident individual makes such an option, he would also have to include in the income subject to the marginal Personal Income Tax rates all other capital gains.

2. Companies

Capital gains derived by Portuguese resident companies are included in the computation of the taxable profit, which is subject to a CIT rate of 23% increased by a 3% state surcharge applicable to the taxable profit exceeding € 1,500,000, a 5% state surcharge applicable to the taxable profit between € 7,500,000 and € 35,000,000 and a 7% state surcharge applicable to the taxable profit exceeding € 35,000,000. The CIT final rate should also be increased by a municipal surcharge at a rate up to 1.5%, depending on the municipality where the company is located.

Resident taxpayers with a commercial, industrial or agricultural activity as main business qualifying as a small or medium company under with Law no. 372/2007, of November 6, are subject to a corporate income tax rate of 17% on the first € 15.000 of taxable profit, and 21% on the remaining taxable profit. The reduced corporate income tax rate is subject to the minimis aid rules defined in the Commission Regulation n. 1998/2006, of December 15.​

Contudo, as mais-valias poderão beneficiar de uma isenção, independentemente da percentagem de participação transmitida, desde que digam respeito a partes sociais detidas ininterruptamente por um período não inferior a 24 meses, e que, na data da respetiva transmissão, a participação direta ou indireta detida não se revele inferior a 5%.

Additionally, capital losses are not deductible for tax purposes regarding the amount of the loss that corresponds to distributed profits or reserves and capital gains deriving from the disposal of shares to which it was applicable the participation exemption, the international economic double taxation credit, in the same tax period or in the previous four. 

B) NON-RESIDENTS

Under the Portuguese domestic rules, capital gains are exempt from taxation in Portugal if the investor (whether an individual or a corporate entity) has no permanent establishment therein to which the capital gain should be attributed and, additionally, none of the following situations are met:

• The non-resident company is held in more that 25% by an entity resident in Portugal;
• The non-resident individual or company is resident in a tax heaven;
• The disposed participation relates to (i) a Portuguese resident real estate company (a company in which more than 50% of its assets consist of real estate located in Portugal) or (ii) a resident company holding such a real estate company.

Nevertheless, in cases where these requirements are not met, capital gains may still be exempt from taxation under a relevant DTT entered into between Portugal and the country where the individual or the company is resident.​​