New Tax Regime for Crypto-Assets under the Personal Income Tax for 2023 in Portugal: brief summary

20 min readDec 30, 2022

I. Introduction

A. Definition of crypto-asset

· The tax regime for crypto-assets within the scope of the personal income tax contained in the proposed state budget for 2023[1] was changed by the proposed amendment presented by the political party PS on 11.11.22[2] (approved in parliament on 11.23.22 ). Unlike the initial proposal, which included serious inaccuracies, the new regime (which is still far from perfect) appears to respond to some practical questions and presents exemptions that, eventually, may contribute to boosting the development of this sector in Portugal.

· For the purposes of the Portuguese personal income tax code (CIRS)[3], crypto-assets are considered to be “any digital representation of value or rights that can be transferred or stored electronically using distributed ledger or similar technology” (art. 10, para. 17, of the CIRS). This definition seems to meet the standardizing position adopted in the MiCA Regulation[4] (art. 3, para. 2, of the CIRS).

· Art. 10, para. 18, of the CIRS, also excludes NFT’s from the concept of crypto-assets, so we are left without the concept of NFT, as well as without the respective tax framework.

B. The moment of birth of the tax obligation

· A common question in all crypto-assets-related transactions, whether issued or not, is the question of when the tax liability arises, i.e. what is the taxable event. On the one hand, it can be considered the moment when the crypto-assets gains are available on the respective platform (after they are no longer withheld by the transaction that generated them). On the other, it can be the exchange of crypto-assets into legal tender still on the platform (still on the platform and before transferring the converted funds to the traditional bank account). The legislator opted for the second option.

· As long as trading platforms do not contribute to the users’ tax compliance (with official records and statements), nor the users themselves have the means to do so (given the inexistence of official records and statements and the difficulties in monitoring the high price volatility of this type of asset), everything indicates that the first option clash with the proportionality principle.

· The ability-to-pay principle also requires that the increase in assets must represent a real and effective increase in the taxpayer’s assets, so, for now, the moment of birth of the tax liability seems to coincide with the exchange of crypto-assets into legal tender still within the platform, and this seems to be the relevant criterion (whether or not this fund is transferred to a traditional bank account).

· As we will better analyze below, these are the terms that result from arts. 10, para. 20 (category G — capital gains), art. 31, para. 17 (category B — self-employed income) and art. 5, para. 11 (category E — capital income), all from the CIRS. Under the terms of these articles, the taxable event coincides with the moment of exchange of the crypto-asset into fiat currency, that is, with the moment of the profitable disposal of the crypto-asset (regardless of the category).

· With the entry into force of the MiCA Regulation and the future implementation of the eighth amendment of Directive 2011/16/EU (on administrative cooperation in the field of taxation)[5] through DAC8[6], as well as the OECD Crypto-Asset Reporting Framework (CARF)[7], this scenario may change, as they establish information reporting duties for crypto-asset service providers and new rules regarding the exchange of cross-border tax information related to crypto-asset holders.

II. Profitable disposal of cripto-assets — category G (capital gains)

A. Profitable disposal of cripto-assets that do not constitute securities: payment tokens, utility tokens & stablecoins, etc.

· As stated in the initial state budget proposal, gains from the profitable disposal of crypto-assets that do not constitute securities will now be considered as capital gains at 28% for personal income tax purposes. Gains obtained, as well as losses incurred, resulting from the profitable disposal of crypto-assets held for a period of 365 days or more are excluded (art. 10, para. 19, of the CIRS). This period can be counted before the law comes into effect (January 1, 2023), so the new regime applies to crypto-assets acquired before and after January 1.

· With the alteration of the initial state budget proposal, the legislator clarified what is meant by “profitable disposal” for this purpose, i.e. whether we should include in this concept the exchange of crypto-assets into legal tender and the coversion of crypto-assets to other crypto-assets, or only the first option. The answer to this question resulted from the answer to the question of the moment of birth of the tax obligation.

· Pursuant to art. 10, para. 20, of the CIRS, when the 365-day exemption of para. 19 of the same article does not apply and the consideration received for the disposal takes the form of crypto-assets, there is no taxation. In this case, the acquisition value of the delivered crypto-assets is assigned to the crypto-assets received. At the same time, with each conversion of crypto-assets for other crypto-assets, the accounting for the 365-day period starts again. If the crypto-assets received are exchanged into fiat currency, the capital gain to be taxed will be counted based on the original acquisition value, regardless of the number of exchanges subsequent to the original acquisition. This is the result of art. 43, para. 6, of the CIRS, considering that, for the purposes of the profitable disposal, the first acquired crypto-assets are considered the exchanged crypto-assets (first in first out rule — FIFO). Whenever crypto-assets are deposited in more than one credit institution, financial company or crypto-asset service provider, the rule provided for in art. 43, para. 6, of the CIRS, is applicable by reference to each of these entities (art. 43, para. 7, of the CIRS)

· In practice, everything indicates that whenever any taxpayer is satisfied with the gains in crypto-assets, it is enough to convert those gains to a certain stablecoin (with a view to stabilizing the value and mitigating the risk of volatility) and wait 365 days to proceed with the exchange of the stablecoin into fiat currency and, thus, enjoy the tax exemption (this being, basically, the result of the legislator having chosen not to distinguish between stablecoins and crypto-assets in general).

· In this regard, it should be noted that, pursuant to art. 10, para. 4, subpara. a), of the CIRS, in general, the amount of income classified as capital gains (art. 43, para. 1, of the CIRS) subject to personal income tax “consists of the difference between the realization value and the purchase price”. To the acquisition value are added the necessary and effectively incurred expenses, inherent to the acquisition and disposal (art. 51, para. 1, subpara. b), of the CIRS).

· Still according to art. 43, para. 5, of the CIRS, when calculating the amount subject to income tax, losses are not included if the counterparty to the transaction is headquartered in one of the countries, territories or regions with a clearly more favorable regime (listed in accordance with the criteria established by art. 63-D, para. 1 or 5, of the General Tax Law — LGT[8]).

· In this context, emphasis is placed on the anti-abuse clause that establishes the inapplicability of the exemptions resulting from para. 19 and 20 of art. 10 of the CIRS, to persons or entities residing in States or jurisdictions with which a convention, bilateral or multilateral agreement that provides for the exchange of information for tax purposes is not in force (art. 10, para. 21, of the CIRS).

· Finally, according to art. 10, para. 22, of the CIRS, the loss of resident status in Portuguese territory is equivalent to an profitable disposal (exit tax). In this case, the income is determined by the positive difference between the market value on the date of loss of resident status and the acquisition value, taking into account the value of the necessary and effectively incurred expenses inherent to the acquisition (art. 43, para. 10, of the CIRS).

B. NFTs & F-NFTs

· Under the terms of the new art. 10, para. 18, of the CIRS (introduced by the amendment of the State Budget proposal for 2023), unique and non-fungible crypto-assets are excluded from the general concept of crypto-asset contained in art. 10, para. 17, of the CIRS.

· If this were not the case, due to the extraordinarily broad concept of crypto-assets, gains from the sale of NFTs such as, for exemple, digital collectibles (digital art on NFTs) or even online game tools, could be subject to taxation under category G, which at the time of publication of the first proposal raised numerous questions.

· It turns out that the exclusion of NFTs from the general concept of crypto-assets also raises numerous questions. Firstly, if they are excluded from the general concept and from category G, do production and sale or purchase and resale activities continue to fall under category B (like what happens with the professional activity of trading)? If not, does that mean that, at the moment, any type of income from NFTs is not subject to any type of taxation in Portugal? And if they fit, should all NFTs be treated equally, or is it necessary to take into account the nature of the rights that are digitally represented?

· However, there is a type of NFT’s that, perhaps, may be covered by the general concept of crypto-assets, namely Fractional NFT’s (such as, for example, Fractional Real Estate NFT’s), as they can be considered “unique” or “infungible”. F-NFT’s consist of an NFT that has been divided into multiple parts, each of which can be held by a different owner. In general, “fractionalization” occurs via smart contracts which, in turn, generate a certain number of tokens connected to the original, to be sold. However, this “fractionalization” can be reversed and what is no longer “unique” and “unfungible” can become so again. In certain cases, the smart contract can establish a buyout option, which allows the investor to acquire the remaining fractions for a certain price. On the other hand, the smart contract can also establish a buyback option, which allows the holder of the original NFT to repurchase the fractions in a kind of virtual auction. In this sense, everything indicates that the taxpayer will once again benefit from some margin with regard to his tax planning.

C. Metaverse: Digital Real Estate (NFTs)

· In the case of asset-backed securities representing digital real estate (in the scope of the metaverse), it seems that the disposal of such crypto-assets effectively implies the partial or total loss of substance, as happens, moreover, in the case of the traditional real estate purchase and sale regime.

· However, given the exclusion of NFT’s from the scope of application category G, everything indicates that, for now, this type of business is not subject to taxation. The same seems to apply to other types of associated income, such as, for example, those from digital real estate leasing via metaverse, also due to the lack of a legal framework (regardless of whether the income is obtained in crypto-assets or in fiat currency).

D. Profitable disposal of cripto-assets that constitute securities: security tokens

· The qualification as a security token depends on a case-by-case analysis and the fulfillment of the respective requirements in light of the applicable legislation, as follows from the cautious position adopted by the CMVM[9].

· As with traditional securities financial instruments, the acquisition of security tokens also aims at the pursuit of profit, and this profit may derive from its transaction a posteriori (in the form of venture capital), from a remuneration (periodic or unique) or from other advantages derived from the economic activity of third parties or from the exercise of economic rights inherent thereto.

· In the case of a subsequent transaction, i.e., the profitable disposal of crypto-assets that constitute securities, in principle, art. 10, para. 1, subpara. b), of the CIRS, concerning the profitable disposal of shares and other securities, should be applied.

E. Practical problems

· The Tax Authority may ask the holder to justify income obtained with crypto-assets, even if he is not obliged to declare them for personal income tax purposes. Therefore, an updated and as complete as possible documentary support should be kept (which may include proof of transfer of traditional bank account, movement statements of traditional bank account, any type of correspondence exchanged with the platform, emails sent by the platform confirming deposits or transactions, screenshots of messages exchanged via chat support, all documents that can be extracted from the platform, regardless of the type of file, including movement or transaction statements in excel files, screenshots of movement, account, transaction, conversion, winnings statements taken from the platform, etc.).

· This possibility exists, especially if the holder acquires some assets or has expenses considered high in relation to his income. The Tax Authority controls the “manifestation of wealth” of each taxpayer if it detects an increase in wealth.

III. Crypto-related Operations — category B (self-employed income)

A. Context

· In category B, the income earned is not taxed according to the origin of the income, but according to the exercise of an activity, which is determined by its “habitually” and by the “orientation of the activity to obtain profits”.

1. Concept of habitually

· In order to determine the habitualness of a professional or business activity, it is not sufficient to determine whether the activity is habitual, sporadic or unique, but whether the activity is exercised in a stable and regular manner, whether it is associated with a professional structure that requires investment and expenses (such as, for example, the implementation and maintenance of proper facilities for the exercise of the activity or even training, certification or qualifications in the area) and if it is exercised as a means and livelihood or if there are other sources of income that, at least, can cover ordinary expenses and, possibly, also extraordinary ones (for the purpose of determining the economic weight of the activity).

2. Profit orientation of the activity

· The profit-oriented criterion consists of the intention to generate and add income, that is, the income was generated intentionally and not fortuitously or casually, and future economic benefits are expected from a particular professional or business activity or commercial act.

B. Operations related to the issuance of crypto-assets

1. Scope

· Pursuant to the new subparagraph o) of number 1 of article 4 of the Portuguese tax income code (“operations related to the issuance of crypto-assets, including mining, or the validation of crypto-assets transactions through consensus mechanisms”), once the criteria for this purpose have been met, the issuance of crypto-assets through mining or the validation of crypto-assets transactions through consensus mechanisms (staking) will fall within the scope of commercial and industrial activities.

· This new subpara. o) could (or should?) have been changed to “(o)operations related to the issuance of crypto-assets, including mining OR OTHER operations to validate crypto-asset transactions through consensus mechanisms”. The absence of the concept of “mining” and “validation of crypto-asset transactions through consensus mechanisms” (which, in essence, is one of the functional characteristics of mining) is also noteworthy.

· Intentionally or unintentionally, this new subparagraph may include activities that, in principle, may not have the necessary functional characteristics to meet the criteria to qualify as a professional or business activity, such as, for example, the airdrop “activity”.

· Regarding the determination of taxable income, within the scope of the simplified accounting system, the tax falls only on a part of the annual gross income and not on its entirety. Pursuant to art. 31, para. 1, subpara. a) and d) of the CIRS, the determination of the taxable income is obtained by applying the coefficients of 0.15 to operations with crypto-assets and, separately, of 0 .95 to income from crypto-mining. Everything indicates that “operations with crypto assets” can include issuing and non-issuing operations, such as, for example, on-chain staking, airdrop, trading, etc.

· As stated in art. 31, para. 17, of the CIRS, in both cases (subpara. a) and d), of para. 1, of the same article), the taxable event coincides with the moment of the exchange of the crypto-asset into fiat currency, that is, with the moment of the profitable disposal of the crypto-asset, applying, with the necessary adaptations, the terms of para. 20 of art. 10 of the CIRS (category G).

· As an exit tax, the cessation of activity and the loss of status as a resident in Portuguese territory is now equated with the profitable disposal of crypto assets, that is, their conversion into fiat currency (art. 31, para. 18 , subpara. a) and b), of the CIRS).

2. Crypto-Mining

· Very briefly, we are dealing with a procedure for updating the decentralized data recording network via universal verification/ validation of new registrations, based on a multilateral consensus mechanism. The classification of mining activity in category B does not raise major problems (essentially due to the professional structure that such activity requires, both in terms of technical knowledge and in terms of costs with the implementation and maintenance of facilities and hardware).

3. Staking On-Chain

· The classification of staking “activity” under category B raises many questions. Broadly speaking, staking is a way of receiving rewards for holding certain crypto-assets, which in turn are used to validate transactions through consensus mechanisms.

· However, in practice, there are two distinct classifications: on-chain staking and off-chain staking (and both of these classifications can include other sub-classifications, which can make analysis difficult).

· In general, if the taxpayer uses its own hardware to validate transactions directly within a given decentralized network (on-chain), which requires a minimum initial investment, technical knowledge and the existence of a professional structure that generates charges, it may be considered active income (category B).

4. Airdrop

· With regard to airdrop activity, unless we are dealing with the performance of a certain promotional task exercised on a stable and regular basis, generating charges, everything indicates that we are not dealing with a business activity, which falls under category B, but rather with the application of crypto-assets that generates passive income (sporadic and irregular), possibly falling under category E.

· Often, there is not even any intention on the part of the taxpayer to obtain the status of beneficiary (which may occur fortuitously and casually, simply because he holds a certain number of the crypto-assets in question, without even being aware of it), so there is not even any profit-oriented activity either.

C. Other operations related to crypto-assets

1. Scope

· No mention is made of other crypto-related transactions that, in principle, could also be considered professional or business-like activities, such as trading, producing and selling NFTs, or even buying and reselling NTFs.

· Furthermore, as mentioned above, with the exclusion of the NFTs from the general concept of crypto-assets and given the lack of a concept of its own, doubts multiply.

2. Trading

· In theory, everything indicates that a taxpayer engaged in crypto-assets trading, that is, an activity of buying and selling crypto-assets (exchange of crypto-assets into legal tender) with a clear habitual character and with a clear profit- oriented activity, will continue to be classified under category B, as stated in the only official guidance on this matter to date (pre-2023 State Budget), which results from a binding information issued by the Tax Authority under case n.º 5717/2015[10].

3. Production and sale of NFTs

· Theoretically, in case the holder performs a habitual and profit-oriented activity of producing NFTs with the intention of generating income through the sale of NFTs, i. e., the conversion of the NFT into fiat currency or even crypto-assets, eventually, it seems that we are dealing with a business or professional activity and, as such, that the gains obtained as a result of such activity fall under category B.

· Please note that, in certain cases (taking into account the digitally represented rights), the usual and stable activity of producing and selling NFTs places the original holder in a legal situation similar to that of the original copyright holder, so that the resulting income (e.g., in the form of royalties) may be classified as intellectual property income (category B).

4. Purchase and resale of NFTs

· All other subsequent holders whose habitual and stable business activity consists of buying and reselling NFTs (similarly to what happens with the trading activity) and, for example, carry out resales for which, in the form of a commission, receive other NFT’s or cryptoa-ssets or, in the form of royalties, a percentage of crypto-assets via smart contracts, In theory, can also be classified as intellectual property income (category B).

D. Pratical Problems

· The taxpayer is also obliged to comply with the reporting obligations set out in art. 3, para. 6, of the CIRS, i.e. to issue an invoice or equivalent document (electronic invoice-receipt) whenever it sells or provides a service, as already stated in the binding information issued by the AT in cases n.º 14763[11] and 14436[12].

· In this regard, there are some doubts regarding the completion of the receipts, since, in principle, there is no buyer. In this case, the receipt should be filled in with the available information.

IV. Passive remuneration arising from operations related to crypto-assets — category E (capital income)

A. Context

· Among the main implications resulting from this option by the legislator, the changes introduced in category E stand out. Despite the reference to “any forms of remuneration resulting from operations related to crypto-assets” in subpara. u) of para. 2 of art. 5 of the CIRS, seems to cover remuneration in fiat currency and also in crypto-assets, para. 11, of the same article, excludes the taxation of remuneration in crypto-assets from the scope of category E and establishes the moment of the profitable disposal (sale/ conversion of the crypto-assets obtained into fiat currency) as the moment of birth of the obligation tax.

· In the DeFi ecosystem, there are rare cases in which remuneration is paid directly in fiat currency. In most cases, remuneration is paid in percentages of crypto-assets, so that, in practice it seems that the number of cases in which passive income from crypto-assets related operations will actually be taxed under category E will be negligible.

· All income from crypto-assets that, until the present year 2022, in theory, could be classified and taxed under category E (such as, for example, those from airdrop, staking off-chain, mining-apps, lending, yield farming, liquidity mining, NFT staking, crypto savings accounts, etc.), continue to be classified under category E, but are now taxed as a capital gain (category G) and only at the time of the profitable disposal (art. 10, para. 20, of the CIRS).

· This, if the exemption relating to “crypto assets held for a period equal to or greater than 365 days” provided for in art. 10, para. 19, of the CIRS is not applicable. Between the scope of application of the first and second exemptions, everything indicates that the taxpayer now benefits from “some” margin in the management of his private assets.

· In this sense, establishes art. 101-B, para. 5, of the CIRS, that the income provided for in subpara. u) of para. 2 of art. 5, also of the CIRS, is exempt from withholding tax, except in the case of income listed in subpara. a) of para. 1 of art. 71 of the CIRS, that is, the capital income obtained in Portuguese territory, by residents or non-residents, paid by or through entities that have their headquarters, effective management or permanent establishment also in Portuguese territory, which are responsible for the payment and have or must have organized accounting.

B. Crypto-Mining-Apps

· In the case of mining apps, we are not facing the exercise of any activity, but rather the obtaining of fruits (passive income) that result from the normal automatic operation of a given mobile application.

· In most cases, this type of “activity” does not even require any type of initial financial investment, either in crypto-assets or in legal tender (it only requires the processing capacity and energy that the mobile application needs to operate).

C. Staking Off-Chain

· If the taxpayer does not use the hardware itself and simply uses a crypto-assets trading platform (such as Binance or Coinbase, for example, which can simply be accessed via a mobile device) to make a temporary crypto-assets application called staking and obtain the respective fruits (off-chain), in principle, we may consider this to be passive income and, as such, subject to category E.

· As explained above, the gains (fruits) obtained seem to result from the operation of the platform (which uses the applied assets to validate transactions) and not from the exercise of an activity by the holder of the applied crypto-assets.

D. Airdrop

· In principle, this is simply a financial application of crypto-assets that generates passive income that fits into category E.

· At least, this is what results from the sporadic, irregular, fortuitous and casual nature of this income, as explained above with regard to category B.

E. Security Tokens Dividens

· As with securities, it is possible to distinguish the various sub-classifications that security tokens present. For example, holding the security tokens sub-classification, called equity tokens, may entitle the holder to receive dividends.

· As a rule, any fruit arising from a private, patrimonial legal situation, regardless of the form or legal qualification of the structural type of the underlying business, is a taxable event for capital income, as long as it does not impair the substance of the source, nor is it liable to be taxed under other categories.

· As such, any fruits that are generated by equity tokens by way of dividends and meet these requirements can, in principle, be taxed under category E.

F. NFT Dividends

· There are NFTs that constitute their holders in atypical and differentiated legal situations. It is possible to camouflage complex financial legal situations identical to traditional securities through the guise of NFT, similar to equity tokens (especially in the case of F-NFTs). As such, in principle the fruits obtained can be taxed in category E.

G. NFT Staking

· In general, NFTs can be applied (deposited) in a given decentralized network, in order to obtain via smart contracts daily, weekly or monthly rewards in percentages of crypto-assets (often the utility tokens of that platform, which in turn are convertible into other types of crypto-assets or even tradable in the secondary market).

· Also in this case, it does not seem reasonable to classify this “activity” under category B or G, since we are dealing with passive income that does not harm the substance of the source and can be classified under category E.

H. Lending

· This operation consists of a loan in crypto-assets (deposited in a certain decentralized network for this purpose), remunerated via smart contracts on a daily, weekly, or monthly basis through a certain percentage also in crypto-assets (usually of the same kind as the loaned crypto- asset), possibly falling under category E.

I. Yield Farming & Liquidity mining

· In this case, we are dealing with a blocked deposit of crypto-assets in a certain “pool” (like an investment fund), together with other users, in order to obtain, via smart contracts, rewards or interest in percentages of crypto-assets of a certain project. As such, it also involves an initial financial investment, but in principle they do not require the exercise of any business or professional activity by the holder of the crypto-assets invested or even charges, so everything indicates that we are dealing with passive income.

J. Crypto Savings Accounts

· Crypto savings accounts (f. g. Binance Simple Earn) consist of the flexible or blocked deposit of crypto-assets in the investment portfolio, in order to obtain via smart contracts rewards or interest in crypto-assets percentages.

· This service is offered by most trading platforms as an alternative to traditional holding (from which only gains in terms of capital gains resulting from price fluctuations are taken).

V. Conclusion and future prospects

· In global terms, everything indicates that we have moved from a highly comprehensive OE proposal for 2023 that, eventually, could generate irreparable dysfunctions and distortions in the economic and financial system, to a highly competitive proposal, which seems to present the necessary conditions to maintain Portugal on the list of countries considered crypto-friendly.

· However, it is clear that the legislator and the regulatory and supervisory authorities themselves seem unable to ensure a clear distinction between the various classifications and sub-classifications of crypto-assets, both in legal and tax terms.

· As if this were not enough, in addition to the above, there are more and more situations to be taken into account (not developed in this newsletter), among which are the problems related to VAT, the subjection of free transfers of crypto-assets to stamp duty (10%), the uncertainties regarding international taxation (state of the source of income or residence of the taxpayer), possible capital gains arising from exchange of crypto-assets for real estate, among many other relevant situations.

· There is thus a considerable increase in the importance of the increasingly complex and time- consuming case-by-case analysis, both in assessing the activity in question and the type of crypto-assets or its tax framework.

This text is for informational purposes only and does not constitute any type of legal advice, nor does it establish a client/ representative relationship between the reader and the lawyer who authored the text.

Lisbon, December 30, 2022

Diogo Pereira Coelho

[1] Accessible at: https://www.parlamento.pt/ActividadeParlamentar/Paginas/DetalheIniciativa.aspx?BID=152005

[2] Acessible at:

https://app.parlamento.pt/webutils/docs/doc.pdf?Path=6148523063484d364c793942556b356c6443397a6158526c63793959566b784652793950525338794d44497a4d6a41794d6a45774d544176554545765a444e6c4e6d4d354d6d49744f444e6d59533030596d59304c546b7a4d4451744e6d51324d5441334e6a6468596d45784c6e426b5a673d3d&Fich=d3e6c92b-83fa-4bf4-9304-6d610767aba1.pdf&Inline=true

[3] Accessible at: https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/codigo-do-irs-indice.aspx

[4] Accessible at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020PC0593

[5] Accessible at: https://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A32011L0016

[6] Accessible at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52022SC0401&qid=1670936134550

[7] Accessible at: https://www.oecd.org/tax/exchange-of-tax-information/crypto-asset-reporting-framework-and-amendments-to-the-common-reporting-standard.htm

[8] Accessible at: https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/lgt/Pages/lei-geral-tributaria-indice.aspx

[9] Accessible at: https://www.cmvm.pt/pt/AreadoInvestidor/Faq/Pages/FAQs-Criptoativos_industria.aspx