On 22 August 2016, Portugal published Law-Decree no. 47/2016, which introduces changes to the Tax Code concerning the country's patent box regime (50% reduction of qualifying taxable IP income). The amendments bring the regime in line with the modified nexus approach developed as part of BEPS Action 5, which requires that the benefits received under a regime be aligned with the actual activities performed by the taxpayer claiming the benefits.
The nexus ratio formula for determining the ben…