Article 12 of Decree-Law No. 157 of 2024 outlines the fundamental calculation for the Qualified Domestic Minimum Top-Up Tax (QDMTT). The tax is determined by multiplying the applicable tax rate by the taxable income. It specifies two key conditions under which the tax liability will be zero: firstly, if the income excluded based on the significance of the activity equals or exceeds the group's total net income; and secondly, if the effective tax rate is equal to or greater than the 15% minimum rate. The article explicitly states that no tax exemptions apply to this tax. Further procedural controls and conditions are deferred to the executive regulations.
Chapter 3 - Tax Imposition and Entitlement
Article 12 - Tax Calculation
The tax on the taxpayer is calculated by multiplying the tax rate by the taxable income.
The tax will be zero in either of the following two cases:
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