02264/20.4BEPRT
AI generated
Administrative court dismisses bank's appeal regarding tax authority's refusal to recognize foreign tax credits for withholding tax.
Legislator summary
AI generatedThe Administrative Court of Appeal unanimously dismissed the bank's appeal against the Tax and Customs Authority's decision. The bank argued that it should be able to offset foreign withholding taxes against its Portuguese tax liability, but the authority refused this recognition. The court ruled that the specific conditions for such tax credit recognition were not met under the applicable domestic law.
Legislator headnote
OfficialBANCO CONTRIBUIÇÃO FINANCEIRA
Keywords
AI generated
foreign tax credit
withholding tax
tax offset
international treaty
administrative appeal
tax authority
double taxation
Cited Legislation
AI generatedArt. 164.º do CIRC
Art. 10.º da Lei n.º 66/2007
Full text
[Nº CONVENCIONAL] JSTA000P30943
[Nº DO DOCUMENTO] SA22023050302264/20
[RECORRENTE] BANCO 1... S.A.
[RECORRIDO 1] AT – AUTORIDADE TRIBUTÁRIA E ADUANEIRA
[URL] https://www.dgsi.pt/jsta.nsf/35fbbbf22e1bb1e680256f8e003ea931/CF3713025D178CA0802589A5003EBDFD?OpenDocument