Within the scope of the moratorium related to credit operations provided for in Decree-Law no. 10-J / 2020, of 26 March, the Tax Authorities (AT), through Tax Circular no. 6/2020, of 7 April, clarified the following:

1.   Extensions and suspensions of credit operations must be treated, for IS purposes, as changes to the term of the contracts. IS will only be due on the initial capital loan in case a higher rate applies considering the new duration of the contract (in view of the rate applicable based on the original duration).

2.   The capitalization of interest should not be treated as using credit for IS purposes.

3.   IS is not due as a result of the change in the term of the guarantees, insofar as they are ancillary to credit agreements.

Text prepared in accordance with the legislation in force on 9 April 2020.