🇵🇹 Portugal Company Formation
Madeira MIBC at 5% CIT, IFICI regime at 20% flat PIT, and IP Box with 85% exemption. EU membership with path to citizenship in 5 years.
Updated April 2026
Madeira CIT
5%
IFICI PIT
20% flat
IP Box Exemption
85%
Tax Treaties
80+
Citizenship
5 years
Tax System
Rates and incentives
| Tax | Rate | Note |
|---|---|---|
| Corporate income tax (Mainland) | 21% | Standard rate. Reduced to 15% for SMEs on first EUR 50,000. 12.5% for inland territories. |
| Madeira MIBC | 5% | EU-approved reduced rate until at least 2027. Requires job creation and qualifying international activity. |
| IP Box (Patent Box) | ~3% | 85% exemption on qualifying IP income. OECD nexus approach. Covers patents and copyrighted software. |
| IFICI personal tax | 20% | Flat rate for 10 years on Portugal-source income from qualifying activities. Replaced NHR from 2024. |
| Withholding — dividends | 25% | EU Parent-Subsidiary Directive applies (0% for qualifying EU parents). Treaty rates as low as 5%. |
| VAT | 23% | Standard rate. Reduced rates of 6% and 13% for specific goods and services. |
Why Portugal
Key advantages
Madeira MIBC — 5% CIT inside the EU
EU-recognized state aid regime for international businesses. 5% corporate tax rate for qualifying companies with job creation in Madeira. Valid through at least 2027.
IFICI regime — 20% flat PIT for 10 years
Replacement for NHR. 20% flat personal income tax on Portugal-source income from qualifying activities — tech professionals, researchers, entrepreneurs, and investors.
IP Box — 85% exemption on qualifying income
Patents and copyrighted software income taxed at approximately 3% effective rate. OECD-compliant nexus approach. R&D must be performed in Portugal.
EU citizenship in 5 years
One of the shortest paths to EU citizenship. Portuguese passport ranks among the world's strongest with 186 visa-free countries.
80+ double tax treaties
Extensive DTA network including US, UK, Brazil, China, Germany, and all major EU partners. Strong Lusophone connections with Brazil, Angola, and Mozambique.
What We Build
Full scope of implementation
- ✓Madeira MIBC company registration with SDNCOM licensing
- ✓NIF application and IFICI regime registration
- ✓Substance setup — local employee (mandatory for MIBC), registered office
- ✓Golden Visa or D7 Passive Income visa coordination
- ✓Corporate bank account — full KYC file and compliance dossier
- ✓Annual compliance — accounting, IES filing, and corporate tax returns
- ✓Transfer pricing documentation for intragroup transactions
Who This Is For
Ideal client profiles
2025 – 2026
What has changed
⚠ NHR regime revoked — IFICI replaces it from 2024
New applicants cannot access the old NHR regime. IFICI offers 20% flat PIT but only for qualifying activities — not a universal benefit. Grandfathered NHR holders retain their status.
CIT rate reduced to 19% for 2025/2026
Portugal is progressively reducing the standard CIT rate. SME rate lowered to 15% on first EUR 50,000. New 12.5% rate for inland territory SMEs.
Pillar Two — Global Minimum Tax implemented
IIR from 2024 and UTPR from 2025. May affect the viability of Madeira MIBC for MNE groups with consolidated revenue above EUR 750M.
Common Questions
FAQ
Can I still get NHR status in Portugal?
No — NHR is closed to new applicants from 1 January 2024. Existing NHR holders are grandfathered. The replacement is IFICI, which offers 20% flat PIT for 10 years but is restricted to qualifying activities (technology, scientific research, high-value professions). Not everyone qualifies.
What qualifies for the Madeira MIBC 5% rate?
International business activities — services to non-Portuguese-resident clients, export-oriented trading, and certain IP exploitation. Requires job creation within 6 months and qualifying investment within 2 years. Income from intra-EU transactions may not be eligible.
What is the effective tax rate for e-commerce without IFICI?
High — approximately 43% to 48% combined (21% CIT + 28% PIT on dividends + municipal and state surtaxes). Portugal is only attractive for founders who qualify for IFICI or whose business generates IP Box qualifying income.
How does the Golden Visa work now?
Direct real estate investment in Lisbon and Porto is restricted. The fund investment route remains — EUR 500,000 in qualifying venture capital or investment funds. Minimal physical presence required (7 days per year). Path to citizenship after 5 years with basic Portuguese language.