Autonomous Region of Madeira, or just Madeira, is one of the two autonomous regions of Portugal. it is well known for it is wine, gastronomy, historical and cultural value, flora and fauna, landscapes (laurel forest) that are classified as a UNESCO World Heritage Site, and embroidery artisans. But these are not the main reasons to start a business in Madeira.
Special status within European Union
Although Madeira is part of Portugal which is a Member state of the EU, due to its geographical situation Madeira is entitled to derogation from some EU policies despite being part of the European Union. Consequently, The International Business Center of Madeira (IBCM or MIBC), formally known as the Madeira Free Trade Zone was established.
Under the current set of tax benefits applicable to the MIBC tax benefits, the applicable corporate income tax rate for licensed companies is 5% of taxable income until the end of 2027. Non-resident single and corporate shareholders of Madeira’s IBC companies will benefit from a full exemption from withholding tax on dividend remittances from the Madeira companies, provided that they are not resident in jurisdictions included in Portugal’s “black list”. No withholding tax on the worldwide payment of interest, royalties and services. Documents, contracts and other operations requiring public registration carried out by IBC companies will benefit from an 80% exemption on stamp (capital) duty, provided that other parties involved are not resident in Portuguese territory or are also companies operating within the legal framework of the IBC of Madeira.
Incorporation of Trusts
The MIBC is the only jurisdiction in Portugal that allows the incorporation of trusts. In accordance with the law, in a Madeiran Trusts, the Settlor shall expressly designate the law that will regulate the Trust. Furthermore, and if desired, it is possible to substitute the chosen law at any time during the Trust’s existence.
The above means that any material change in the elected Law of the trust, will allow that the Trust Deed is simply amended and another Law preferred to regulate the same. If, on the other hand, the Trust would be actually located in said (initial) jurisdiction this would mean that the Trust would have to be re-domiciled (if permitted) or extinguished.
Nevertheless, trusts are not allowed to have, directly, pure financial activity. The following tax benefits apply for a trust incorporate within the MIBC:
- Trusts are fully exempt from taxation on dividends received from shares, royalties or interest received on the deposits;
- All (non-financial) income distributed from the Trustee to the Trust’s Beneficiaries is fully exempt of taxation provided these Beneficiaries are corporate entities licensed to operate within the MIBC or non-Portuguese resident entities/individuals.
International Shipping Register of Madeira
International Shipping Register of Madeira or MAR is directly linked to the MIBC, and offers unique operational advantages. Special tax benefits are applicable to both vessels (excluding fishing vessels), yachts, shipping and yachting companies incorporated in MIBC. These benefits are employee related benefits, benefits for yacht companies and flexible mortgage system applies to vessels register under MAR.
So if you are in trading or holding services, e-business or ICTs or in production, assembling and warehousing business Madeira is just the right place to start or relocate your business to. Apart from that if you are shipping or yachting company, Madeira offers all the benefits that you need.