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On 30 January 2020, Law Proposal 10/XIV was presented by the Portuguese Government to the Portuguese Parliament. It partially transposes the EU’s Anti-Tax Avoidance Directives (ATAD) 1 and 2, respectively Council Directive (EU) 2016/1164, of 12 July 2016, and Council Directive (EU) 2017/952, of 29 May 2017. The remainder provisions of ATAD 1 have already been transposed in Portugal following the publication of Law 32/2019, of 3 May 2019.

Since most of its provisions apply to tax years starting on or after 1 January 2020, taxpayers should start analysing existing structures and transactions that could potentially be affected by these provisions.