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Portuguese to English translations [PRO]
Bus/Financial - Finance (general) / Reclamação Graciosa | | Portuguese term or phrase: tributação dos dividendos à entrada | Dear collegues,
I would like your help with this expression and would need its equivalent in English. I have a possible translation but would be very appreciative of your suggestions of the meaning and correct way to translate it, in order I can confirm the (possible) translation, or not.
CONTEXT:
"(COMPATIBILIDADE COM O TRATADO DA CE DO REGIME PORTUGUÊS DA TRIBUTAÇÃO DOS DIVIDENDOS À ENTRADA), que o regime do art.° 46.° /1 do CIRC se aplica a todos os dividendos distribuídos após 2000, mesmo que provenham de lucros a anteriores à aquisição."
Thanks very much in advance! |
| | | taxing on inbound dividends | Explanation:
[...] jurisprudência em causa decorrem conclusões essenciais relativamente à concepção dos sistemas de tributação dos dividendos: os Estados-Membros não podem estabelecer uma tributação superior para os dividendos entrados do que para os dividendos internos.
eur-lex.europa.eueur-lex.europa.eu
The Commission believes that analysis of this case law leads to fundamental conclusions about the design of dividend taxation systems: Member States cannot levy higher taxes on inbound dividends than on domestic dividends.
eur-lex.europa.eueur-lex.europa.eu
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http://taxbites.be.apache05.hostbasket.com/taxation/pdf/t044...
Belgium taxes inbound dividends the same way. However, under the provisions of Belgium’s double tax treaties, the country where the dividend originates can withhold tax at source on the dividend
before it is paid out. Belgium grants unilateral relief to prevent double taxation by applying the deduction method: The foreign tax credit (FTC) is deducted from the gross dividend before the Belgian
tax is calculated. The Belgian 25 percent withholding tax (or, alternatively, the final income tax) is calculated on the net dividend after deduction of the foreign withholding tax. (See below.)
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Note added at 3 days15 hrs (2011-10-09 14:12:06 GMT) Post-grading
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Jorge & Julie,
Always a pleasure.....
Thanks for being so courteous in your communication here.
Um bom Domingo para vocês ai em Portugal.
Gilmar |
| Selected response from:
 Gilmar Fernandes
United States
Local time: 01:03
| Grading comment Thank you very much for your help, Gilmar! I always like your suggestions/opinions.
It was very useful!
I wish you the very best!
4 KudoZ points were awarded for this answer |
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| Discussion entries: 0 |
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Automatic update in 00:
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4 hrs confidence:   dividend withholding tax at source
Explanation:
uma possibilidade.
Considerei que o "Tratado da CE" é a Directive 2003/49/EC of 3 June, 2003:
(…) (4) The abolition of taxation on interest and royalty payments in the Member State where they arise, whether collected by DEDUCTION AT SOURCE or by assessment, is the most appropriate means of eliminating the aforementioned formalities and problems and of ensuring the equality of tax treatment as between national and cross-border transactions; it is particularly necessary to abolish such taxes in respect of such payments made between associated companies of different Member States as well as between permanent establishments of such companies. (…)
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U.S. Income Tax Treaties
Trends, Issues & Policies
Recent Developments - Future Prospects
(…)
B. DIVIDEND WITHHOLDING AT SOURCE
1. Reduced Withholding at Source
In addition to certain procedural elements of income tax treaties (discussed above), the imposition of (or relief from) WITHHOLDING TAXES AT SOURCE ON CORPORATE DIVIDENDS paid continues to evolve as U.S. treaties are negotiated. Under the U.S. statutory tax rules dividends, when paid from the U.S. to the foreign shareholder, are subject to withholding at source on the gross amount at the rate of 30 percent.84
(…)
For example, in revised treaties with Japan, the United Kingdom, The Netherlands, Mexico and Sweden the WITHHOLDING TAX AT SOURCE ON DIVIDENDS paid by an affiliate to its foreign parent corporation was eliminated, as examined below. The 1996 Model income tax treaty provided for a minimum five percent on such dividends (but the 2006 revision did not implement this zero withholding approach adopted in some treaties).
(…)
A number of the substantive income tax treaty rules are in transition, as noted from various selected OECD and U.S. tax law developments, summarized below. One of the most important substantive changes included in U.S. income tax treaties negotiated on amended over the last several years is the inclusion of a provision reducing the WITHHOLDING AT SOURCE TAX RATE ON DIVIDENDS to zero in those situations involving dividends being paid from a controlled foreign subsidiary to its parent corporation. Many of the substantive benefits provided under an income tax treaty are the reductions of the rate (sometimes to zero) of the withholding tax at source (with the residual taxation occurring at the residence). This is particularly (…)
http://www.law.uh.edu/faculty/wstreng/HoustonInternationalTa...
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Personal income tax
Residents
DIVIDENDS made available in 2011 are subject to WITHHOLDING TAX AT SOURCE at the flat rate of 21.5% on the gross amount.
Optionally, recipients can opt for the inclusion (with their other income) of 50% of the dividend received, in which case the tax withheld is considered to constitute a payment on account of the final tax payable.
Non Residents
Dividends distributed to non-residents are subject to WITHHOLDING TAX at a flat rate of 21.5%.
The 21.5% rate may be reduced in the case of natural persons residing in countries with which Portugal has entered into double taxation agreements, provided that by the end of the period laid down for the payment of the tax which should have been deducted in accordance with applicable legal provisions(…)
http://bpi.bancobpi.pt/index.asp?riIdArea=AreaAccionistas&ri...
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Withholding tax = an amount withheld by the party making payment to another (payee) and paid to the taxation authorities. The amount the payer deducts may vary, depending on the nature of the product or service being paid for. The payee is assessed on the gross amount, and the tax to be withheld (the withholding tax) is computed in that assessment. The purpose of withholding tax is to counteract tax evasion and tax avoidance either by domestic or international taxpayers. In some jurisdictions, the purpose of deduction is also to facilitate or accelerate collection and no assumption about evasion is inferred.
Domestic withholding
Domestic withholding tax is applied to earned income in circumstances where the payee might otherwise avoid declaring the income earned, for example when people work on a contract basis - neither as a registered business nor as an employee. Some countries require the employer to withhold a certain percentage of that person's income and submit it to the tax authority. In these circumstances, the payer is usually a business and would normally have to submit details of the identity of the person from whom this form of tax has been deducted.
(…) Domestic WITHHOLDING TAX is also applied to interest and/or DIVIDEND PAYMENTS, typically at standard rate and paid directly to the Revenue authorities. This secures immediate payment of at least a substantial proportion of the tax due. Individuals whose total income does not exceed the higher rate tax threshold need not then complete a tax return (jurisdiction dependent). (…)
webster-online (me thinks...)
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hth
beatriz_souza
| transl8_2
Brazil
Local time: 02:03
Works in field
Native speaker of:  Portuguese
PRO pts in category: 12
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| | Notes to answerer
Asker: Thank you very much for your research! I will post this question again but I want you to know that I'm not closing this question without garding you for your excelent research. The reason I will do this is because I'd like to hear one or two more opinions from people that could have been slepping at the time of the this posting! THANK YOU so much!!
Asker: Once again, please allow me to recognize and thank you for your research and help! Truly, THANK YOU! I wish you all the best!
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