Portugal–France tax treaty

Article 17 Directors’ fees

Artigo 17.º · Remunerações de administradores e membros de órgãos sociais

Convenção Portugal–França · signed 14 January 1971 · in force 18 November 1972 · English: our translation

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Any remuneration, whether fixed or variable, derived by directors, members of the supervisory board and managing partners of a company by virtue of the exercise of their mandate shall remain subject to the domestic law of each State.

Quaisquer remunerações, fixas ou variáveis, obtidas pelos administradores, membros do conselho fiscal e sócios gerentes de uma sociedade em virtude do exercício do seu mandato continuam sujeitas ao disposto na lei interna de cada Estado.

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Where double taxation arises, it shall be avoided in accordance with Article 24.

No caso de se verificar dupla tributação, esta será evitada segundo o estabelecido no artigo 24.º

Paying or receiving income between Portugal and France? Article 17 may decide where it is taxed.

We apply tax treaties to dividends, interest, royalties, salaries and gains, prepare the relief-at-source form and refund claims, and check structures against the treaty’s anti-abuse rules. A written answer and a fixed quote within one working day.

Unofficial English translation prepared by BCA Portugal for reference. The Convention was done in Portuguese and French and only those texts are authentic. The Portuguese text is reproduced from the official publication. Editorial notes are ours and are not part of the Convention.

Applying the law

Treaty relief between Portugal and France, claimed correctly

Treaty rates are not automatic in Portugal: the recipient must give the payer a form certified by its own tax authority before the tax is due, or claim a refund afterwards. We check which article applies, the rate and the paperwork.

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