CIT
Tax incentive to wage increase
The tax incentive to wage increase (“Incentivo fiscal à valorização salarial”) will apply when there is an increase in the company's average annual base salary, compared to the end of the previous year, of at least 4.7% (previously, 5%).
It also becomes necessary to ensure an average increase of at least 4.7% in the annual basic pay for employees who earn an amount less than or equal to the company's average annual basic pay.
The law also lists an increase in the wage range as a reason for exclusion from access to the benefit.
The costs associated with salary increases will now be increased by 200% (previously, 150%), up to a maximum annual amount per worker of five times the National Minimum Monthly Wage (previously, four times).
Thus, the maximum deduction to the taxable profit per worker is set at € 4,350 (previously, € 1,640).
The capitalisation of companies is now (even) more attractive.
Incentive to the Capitalization of Companies (ICE)
ICE is now calculated by applying the average 12-month Euribor rate plus a spread of 2 percentage points (previously, 1.5 percentage points), regardless of the company's size.
In the 2025 tax year, the incentive rate is increased by 50%, instead of the already foreseen 30%.
PIT
Tax incentive for company recapitalisation
The incentive for individual investment in the capitalisation of companies is strengthened through the possibility of, deducting, for PIT purposes, 20% of capital contributions made in cash from, to the gross amount of profits distributed by that company or, in the case of the sale of this shareholding, from the balance between the capital gains and capital losses realized.
This deduction is no longer conditioned by specific requirements related to the company's economic situation, thus applying to most companies.
However, it will not apply to contributions made to entities subject to the supervision of the Bank of Portugal or the Portuguese Insurance and Pension Funds Supervisory Authority, branches in Portugal of credit institutions, other financial institutions or insurance companies.
Extension
The following tax benefits provided in the Tax Benefits Code (EBF) are extended until 31 December 2025:
Deductions related to partnerships of titles with social impact (Article 19-A);
Tax incentives for forestry activities (Article 59-D);
Forest management entities and forest management units (Article 59-G);
Electrosolar or exclusively electric vessels (Article 59-J).
The extraordinary support regime for costs incurred in agricultural production (Article 240 of Law 82/2023, of 29 December) is also extended until 31 December 2025.
The licensing of entities to operate under the Madeira International Business Centre regime can now be done until 31 December 2026, while the termination date of the regime remains 31 December 2028.
2025 State Budget Law
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2025 State Budget
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