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Dean Sir,

I am born Portuguese in 1970.
Since 1993 I work as an International Law Consultant with a diversify experience mainly in EU and USA.

I am aware that the Portuguese Prime Minister – António Costa- is doing until the end of June, a Commercial Good Will Tour, in USA, in order to draw on with promises to Portugal several USA companies, USA businessmen and USA Consultants to Portugal after BREXIT.
I have no political agenda what so ever, but I am a strong defendant of legality and honesty in this global commercial world of ours.

In nowadays Portugal, it is a fact that the Portuguese Tax Authorities and the Public Attorney Office, will bring to a fiscal and criminal court any and all of USA companies, for not paying tax in Portugal like the Portuguese companies.
The Portuguese tax man do not recognize the Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed by Portugal and USA in September 1994.
Furthermore, many Court Actions were and still are, in increasing numbers, admitted to Portuguese Fiscal and criminal Courts, by the Public Attorney’s Office with the help of the Portuguese Tax Authorities, and, as many Court accusations do testify, the Public Attorney’s Office do consider the USA companies, especially the LLC’s , but not only, equal to “ offshore companies”.

The Portuguese Tax Authorities and the Public Attorney’s Office do not recognize the fiscal LLC’s “ transparent “ statue not either the “ disregarded entity” for IRS statue!
In the Portuguese Courts it appears that the USA Tax Code is not acknowledged by both, the Public Attorney’s Office and the Portuguese Tax Authorities not are both Portuguese entities show any promise to acknowledge a different Tax Code existing in USA.
As a direct result, many businessmen are taking almost of their time in and out the Portuguese Courts and the Portuguese Tax Authorities. This take in average ¾ of their time!

UE do need the experience, the knowledge and the trade with the USA companies and USA businessmen, but not to anchor themselves in Portugal!
Stay in EU for Trade, for business, do give the EU corporations the benefit of the USA consultants, but do not anchor yourselves in Portugal!

Our Prime Minister will be doing a Good will Tour, in order to draw on with promises to Portugal several USA companies, USA businessmen and USA Consultants to Portugal after BREXIT, but do not allow to be lie by the Portuguese Government promises.
Do please continuing to do business in EU, but go to another EU country, like The Netherlands or like Luxembourg. They are in the heart of EU and the European continent, they do acknowledge the Law and the International Agreements and Conventions signed and their Tax Authorities are accustom to deal with international companies, like USA companies.

A quick search in Portuguese Courts Fiscal and Criminal actions do show an impressive raise on Legal actions by the Public Attorney’s Office and the Portuguese Tax Authorities against the USA companies, given them equal status as any “ offshore” blacked listed companies.
One of this case, among sow many others is the Court Case number 2/10.9IFL SB. The sad thing about it, is that it is not the exception…but it is the rule!

Kindest Regards,
Paulo Gonçalves – International Law Consultants for 25 years, nowadays voluntary retired from active professional life.
Mobile + 351 936 500 012
Email. Jpsmgoncalves@sapo.pt

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Income tax slab rates, surcharge for ay 2018-19 and residential status (NRI)
1) INDIVIDUALS INCOME TAX RATES FOR A.Y: 2018-19
2) COMPANIES, FIRMS & LLP INCOME TAX RATES FOR A.Y: 2018-19
3) A.Y. 2018-19 RATES OF SURCHARGE

RESIDENTIAL STATUS AND SCOPE OF TOTAL INCOME
https://goo.gl/jCpQFc
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1/16/18
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