In line with Action 2 recommendations concerning the denial of dividend exemption for deductible payments, the Portuguese CIT Code [see Article 51,10,a)] provides, since 2011, that the elimination of economic double taxation regime [participation exemption (see Articles 51 to 51-D)] was not applicable to payments from profits not subject to effective taxation.
In 2014 this rule was modified and the same regime is now not applicable to tax deductible payments at the distributer entity level and to payments when the distributer entity is not subject to CIT or is exempt of CIT and is not resident in a European Union Member State or in a Economic European Space Member State that is subject to the tax administrative cooperation equivalent to the one established at the European Union level [see article 51,10, respective a) and b)].
Since 2016 this regime was reinforced with a special anti-avoidance rule (see Article 51, numbers 13 and 14).
In the cases where this participation exemption regime can’t be applicable, it´s possible the use of the general tax credit related to the international double taxation (including the economic international double taxation, which is not applicable in the case of entities submitted to a clearly more favourable tax regime), according Articles 91 and 91-A of the CIT Code.  
In 2020 [see Law 24/2020, of 6 July] Portugal modified is CIT Code, according Council Directive (EU) 2017/952 of 29 May 2017 (ATAD 2), amending Directive (EU) 2016/1164 (ATAD 1), as regards hybrid mismatches with third countries. According this amending, a new Subsection I-A (Rules to neutralize the effects of hybrid mismatches), of the Section related to common and various rules, was added to the Portuguese CIT Code, this new Subsection I-A consisting or four Articles, faithfully transposing ATAD 2 rules: (i) Article 68-A, with the relevant definitions of ATAD 2; (ii) Article 68-B, with the rules about hybrid mismatches; (iii) Article 68-C, with the rules about reverse hybrid mismatches; (iv) Article 68-D, with the rules about tax residence mismatches.