Ex-ante the dilemma it is vital to debate trade-off, since it affects a decision. This notion sums up the conflict of choice, ie, the unlikelihood to obtain benefits from a non-choice; however, analysis oughts opportunities strengths and weaknesses. Choosing is literally a daily process as the mundane example denotes: a cheese sandwich or a cake? Of course, choosing depends on individual valuation, chosen criteria and form of analysis (quantitative versus qualitative) but such will not be debated.
Therefore, it is valid to create a holding company (SGPS)? The imperative requires two analytical dimensions: corporate income and imposto selo (IS).
Dividends and similar gains (from capital and interest rates) from shares into Portuguese or European Union (EU) companies are excluded from taxation regardless their volume. But determining taxable profit cumulatively implies the following conditions:
- The investee is an entity based in Portugal or in a Member State subject and not exempt from corporation taxation;
- The minimum time gap, for uninterrupted participation, is one year from the date to profit availability.
Note, to be included on taxable profit, holding shares in entities headquartered in Portugal must reflect a continuous three-year time gap.
Regarding IS, SGPS´s, are exempt on creation moment and capital increases (regardless time). And, such, it is relevant for capital increase procedures or interest exclusively related to cover capital shortfalls in subsidiaries (downward operations) or group (upward operations); in a timespan less than one year.
