Executive summaryOn 12 October 2020, the Portuguese Government submitted the Draft State Budget Law for 2021 (Draft Budget Law) to the Parliament. Among the proposed measures, the Draft Budget Law would: (i) strengthen the permanent establishment (PE) force of attraction principle and also expand the concept of PE; (ii) introduce new Real Estate Transfer Tax rules for the transfer of shareholdings; and (iii) exclude offshore entities from access to public support.Detailed discussionUpdate of the PE conceptThe Draft Budget Law proposes to extend the so-called PE principle of force of attraction. It provides that the income derived from the sale of goods identical or...