[ Offshore Tax ] How are US S Corps taxed in Portugal?
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https://htj.tax/nomad-offshore-summit-2023S Corps are, under certain circumstances, similar to LLCs. Pursuant to domestic legislation, the allocation of income/profits by an LLC shall be deemed as a distribution of dividends, generally subject to 28% PIT in Portugal;
An LLC, being tax transparent, is not deemed resident in the US for the purpose of the DTC with Portugal, and as such, income attributed to LLC’s partners shall not be deemed or treated as dividends for treaty purposes. Rather, it shall be subject to the provisions of Article 24 of the DTC (‘other income’), which attributes cumulative taxing rights to the source and residency contracting states.
The look-through approach adopted in disregard of the LLC for the purpose of applying the DTC provisions does fit entirely with the NHR taxing principles, as the Portuguese tax authorities shall be looking to the nature of the income received by the individual taxpayer rather than the corporate vehicle.
Ultimately, even if the Portuguese tax authorities would deem the LLC/LP eligible for the DTC with the US, the LLC gains could be assimilated to dividends, which pursuant to Article 10 of the treaty, are also taxable in the US, allowing thus, to operate the exemption under the Portuguese legislation.
TIMESTAMPS:
0:00 INTRO
0:10 How are US S Corps taxed in Portugal?
1:15 If a running company in Portugal then it is subject to tax.
1:50 Two options to manage a company in Portugal.
3:16 OUTRO
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So what is, what is needed to know about tax and from the US with just one employee? My wife is a hypnotherapist and registered as an S CORP, but runs much like an LSC. You know this, That's a great question and it's one which we, we encounter all the time as actually speaking to someone about this yesterday and another European country. It's the same principle. Europe has a problem with US entities that are passed through. So these is AEs and S CORP which are more or less pass-throughs. And especially when it's a single member LLC or a single employee or single person quote, it creates an issue. Now on the surface it would be, well, you know, it's taxi US and whatever comes out, let's treat it as dividends and, well in this case, under the NHR, be tax-free. But as we mentioned before, well no, you know, like LLCs and escorts don't do dividends. They do distribution, right? And then so, and management control, there's this thing about a management and control test. If it is a new, oh, in this case, your wife is running that company, she's running the company from within Portugal, then management and control are being exercised from within Portugal. And so therefore Portugal should have been able to tax that company even though it's incorporated in another jurisdiction. Technically it's gonna be subject to task to corporate tests in, in Portugal. So yeah, so it is, it is, it can be quite a complex problem if I'd recommend that you guys seek advice on how to treat it. But basically, you have two options.
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