Under the Portuguese domestic legislation the above withholding tax rate can be reduced to 0% based on the relevant EU directives. Income from the sale of shares in property rich companies will be taxed in the State in which the property is located. Under Cypriot domestic legislation there is no withholding tax on dividends and interest paid to non-residents and where withholding tax on royalties applies, if rights are used in Cyprus, such withholding tax can be reduced to 0% under the relevant EU directives.
