Portugal–United States tax treaty

Article 18 Directors' fees

Artigo 18.º · Percentagens de membros de conselhos

Convenção Portugal–Estados Unidos · signed 6 September 1994 · in force 18 December 1995 · English: authentic text

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Directors' fees and other similar payments derived by a resident of a Contracting State for services performed outside that Contracting State in his capacity as a member of the board of directors or supervisory board (in Portugal, conselho fiscal) or of another similar organ of a company that is a resident of the other Contracting State may be taxed in that other State.

As percentagens, senhas de presença e remunerações similares obtidas por um residente de um Estado Contratante por serviços prestados fora desse Estado Contratante na qualidade de membro do conselho de administração ou do conselho de fiscalização (em Portugal, conselho fiscal) ou de outro órgão análogo de uma sociedade residente do outro Estado Contratante podem ser tributadas nesse outro Estado.

Paying or receiving income between Portugal and the United States? Article 18 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.

The English column is an authentic text of the Convention, reproduced from the Diário da República publication (Resolution of the Assembly of the Republic No. 39/95), checked against the text published by the US Internal Revenue Service. The Convention was done in Portuguese and English, each text being 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 the United States, 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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