OrbitaxPortugal's Supreme Administrative Court Holds All Foreign-Source Income Subject to Municipal Surcharge Unless Attributable to a Foreign Permanent Establishment.
|Approved Changes|Portugal
Portugal's Supreme Administrative Court issued a judgment on 25 February 2026 concerning the levy of municipal surcharge (derrama municipal) on foreign income. The case concerned a company resident in Portugal that challenged the collection of municipal surcharge on its foreign-source interest income earned from debt securities issued by foreign entities. The company argued that the foreign so…