AIP surveyed measures taken in the last decade with tax implications for companies. From this analysis it was possible to draw conclusions, which we now describe.

The tax reform, which includes the progressive reduction of corporate income tax rates and the elimination of surcharges, continues to be postponed. Autonomous Taxation and Extraordinary Sectoral Contributions are aggravated.

Positive sign for the Investment Tax Code and for the deduction from taxable profits of all forms of increase in share capital, measures that are very favorable to the capitalization and downsizing of companies and their international competitiveness.


1. Positive evolution of IRC rates for SMEs and inland areas (in 2020, rate of 12.5% ​​on the first 25 thousand euros of taxable income);

2. In 2020, increase to 12 years the period for reporting tax losses, continuing to be limited to 70% of taxable profits;

3. Special Payment on Account (PEC) – positive evolution since 2017 and possibility of elimination with OE2022;

4. Conventional remuneration of share capital – created in 2016, benefits have been extended; today, the deduction from taxable income of 7% per year, for 6 years, of all forms of capital increases (cash inflows, conversion of credits – shareholder loans, supplementary payments, …, or for the retention of generated profits) is allowed. in the exercise)

5. Frankly positive evolution of the Investment Tax Code - connection with the increase in the attraction of foreign investment; RFAI - Investment Support Tax Regime (with increase in eligible amounts), SIFIDE - Tax Incentive System for corporate R&D (110% deduction), Contractual tax benefits (increase in regional increases) and DLRR - Deduction of Retained Earnings and Reinvested (increase in reinvestment term and maximum deduction amount)


1. Proposal for a 2014 tax reform, which was never implemented, to reduce IRC rates, between 16% and 19%, by 2016, and the elimination of the two surcharges by 2018.

2. State spill - created in 2010. Gradual worsening.

3. Increase in Autonomous Taxation for companies with tax losses and for fringe benefits and vehicle purchase expenses.

4. They were created in 2011 and all extraordinary contributions on the various sectors remain (banking sector, pharmaceutical industry, energy sector; audiovisual and even a Legislative Authorization for a special contribution to the Conservation of Forest Resources)

Lisbon, February 14, 2022