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Portugal Introduces Large Taxpayer Unit

Portugal
21 Mar 2013
The Portuguese Tax & Customs Authority has followed the international trend by setting up a full-fledged Large Taxpayer Unit (LTU) that is responsible for most tax administration functions relating to such taxpayers, including enforcement and tax audit.

Taxand Portugal discovers who the introduction of the LTU will benefit. The following criteria are set as thresholds for companies to be covered by the LTU:

  • Companies with a turnover exceeding: (i) EUR100 million (for entities subject to banking or insurance supervision) and (ii) EUR200 million in all other cases
  • Pure holding companies (so-called SGPS) with income (regardless of being taxable or not) exceeding EUR200 million
  • Companies with a total tax paid exceeding EUR20 million
  • Companies that have relevant corporate relationship with companies covered under the thresholds above
  • Companies included in Group Taxation regime (RETGS), whenever any of the companies of the Group falls under any of the thresholds set out above

The LTU will be responsible for tax audit function in relation to those taxpayers. This will also include the control over all the steps related to the administrative tax procedure (exception for customs and excise duties matters) on any claims involving large taxpayers. The LTU will have a team of 100 fully dedicated account managers that will serve as preferential contact when dealing with the tax authorities.

Discover more: Portugal operationalises the Large Taxpayer Unit


Your Taxand contacts for further queries are:
Fernando Castro Silva
T. +351 218 913 232
E. fernando.castro.silva@garrigues.com

Miguel C Reis
T. +351 226 158 861
E. miguel.c.reis@garrigues.com

Taxand's Take


The LTU exemplifies one further step on the modernisation of the Portuguese tax authorities and it is also expected to represent a positive shift in the relationship between the tax administration and large taxpayers. Following the international trends, the LTU should strive for a more cooperative approach, whereby open dialogue, full disclosure and transparency will lead to timely response to inquiries and requests for information for all parties.

Taxand's Take Author