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Based on the Decree No. 292/2011 issued by the Portuguese Ministry of Finance on 8 November 2011, Cyprus has been removed from the so-called Portuguese “black list” of jurisdictions with privileged tax regimes. The removal has been made in light of the full compliance of both Cyprus and Portugal with the relevant EU Directives such as the EU Directive on mutual assistance in the field of direct taxation.
This development has resulted in a number of positive implications summarized in the table below.
Portuguese CFC Rules: Non-application to CFC rules in respect of Cypriot citizens
Payments from Portuguese entities to Cypriot entities: Deductible for Portuguese tax purposes under the normal rules.
Portuguese capital gains tax: Cypriot entities benefit from the exemption applicable under the normal rules.
Interest income and capital gains from registered debt securities: Generally exempt from Portuguese withholding tax.
Real estate tax payable by Cypriot owners of Portuguese property: Standard rate ranging from 0.2% to 0.8%.
Transfer tax payable by Cypriot purchasers of Portuguese property: Standard rate of 5% / 6.5% on the transfer of rural/urban property.
The removal of Cyprus from the Portuguese blacklist opens up opportunities for Cyprus-Portugal business with tax efficient planning.

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