Jerónimo Martins, SGPS, S.A. informs on Dividend Payment

Note on the dividend tax treatment1

Shareholders resident in Portugal and taxable for PIT (Portuguese Personal Income Tax) are subject to an autonomous tax rate of 28%, unless these Shareholders chose the option of aggregation (50% of the value will then be taxed at PIT progressive tax rates) with his/her other personal taxable income and such dividends are not earned as business or professional income.

Dividends paid to corporate Shareholders, resident in Portugal and taxable for CIT (Portuguese Corporate Income Tax) are subject to a withholding tax rate of 25%, deductible to the amount of CIT payable, unless the dividends are paid or made available to accounts in the name of one or more accountholders, acting on behalf of unidentified third parties. In this case, if the effective beneficiary owner of such dividends is disclosed, the general rules shall apply.

Dividends paid to Shareholders non-resident in Portugal without a permanent establishment in the Portuguese territory, or otherwise having a permanent establishment, but to which the dividends are not attributable, are subject to a final withholding tax (PIT at 28% and CIT at 25%).

The final withholding tax rate shall be of 35% if the dividends are paid or made available to (i) accounts in the name of one or more accountholders, acting on behalf of unidentified third parties, unless the effective beneficial owner of such dividends is disclosed, in which case the general rules are applicable, or (ii) non-resident entities without a permanent establishment in Portuguese territory, which are domiciled in a country, territory or region subject to a clearly more favourable tax regime, according to the list approved by a member of the Government responsible for the finance area.

For the purpose of benefiting from tax exemption, reduction or non-applicability of withholding obligations regarding income taxation, Shareholders entitled to such exemption and benefits should demonstrate and give evidence of all the relevant facts and information required for the discharge or reduction of the withholding obligation, to the financial intermediaries holding the shares registry.