Income from pensions, dividends, royalties, interest and rental income from a foreign source will be exempt from tax, provided that: agreement between the Government of the Russian Federation and the Government of the Republic of Albania to avoid double taxation on income and capital taxes According to AIPEX trustee José Chinjamba, spokesman at a meeting in August , the architecture of the latest generation of APPRI must include the limited definition of investments, “clearly define the assets that need to be protected.” “Clarifications and provisions such as indirect expropriation, fair treatment and the most favoured nation,” as well as the settlement of investor disputes, i.e. transparency in arbitration procedures, open meetings, the publication of documents and public participation by civil society, must also be incorporated into the agreements. Regarding arbitration decisions in the context of foreign investment, Chinjamba indicated that 106 arbitration cases against African states were registered in 2019, amounting to $55.5 billion, of which only $4.6 billion was paid. Currently, the application of double taxation and ways to avoid legal and economic harm are governed by the standards of the tax code. Two legislative provisions to avoid double taxation can thus be envisaged: first, national legislation and, second, international treaties ratified by Portugal. It is advisable to speak with our lawyers in Portugal and ask for legal aid if you set up a business in Portugal or to better understand the tax structure of that country. From the point of view of national tax legislation, in parallel with international tax legislation, it should be noted that the provisions agreed in bilateral tax treaties prevail over the provisions of domestic law in the event of conflict. The Convention on the Prevention of Double Taxation will apply primarily to national law where a non-resident subject meets the application of the convention. In this case, the State of residence is solely responsible for the taxation of the resident`s income, including income collected in the state in the territory from which the subject is foreign to the territory. The classes covered by the agreement are, for Portugal, personal income taxes (IRS), business income (CRI) and Angola, income tax (IRT), industry (II), urban construction (IPU) and capital investment (IAC). When offshoring, we must take into account all relevant aspects, such as tax stays, double taxation agreements, financial emigration rules (if necessary) and details of restructuring investments.
Such agreements are being negotiated with Japan, Ukraine and Belarus.