Portugal vs Netherlands tax in 2026: the three boxes against nine brackets

Residence: facts against days

Dutch residence is a question of facts and circumstances — where the home, the family, the work and the social life are — with no day count in the law. Portugal counts 183 days in a twelve-month window or the day you keep a home that looks like a habitual residence (IRS Code, art. 16.º). Dual residence is settled by article 4 of the 1999 convention: permanent home, centre of vital interests, habitual abode, nationality.

Deregistering from the Dutch municipality (BRP) and giving up the Dutch home are the two facts that end Dutch residence; keeping a house available “for the children” keeps a foot in box 3 and often in box 1.

• Box 1 35,75 % / 37,56 % / 49,5 % on work and home; box 2 24,5 % / 31 % on your own company; box 3 36 % on a deemed return on savings
• Portugal: 12,5 % to 48 % on income, 28 % on capital income and gains, no wealth tax
• 10 % / 10 % / 10 % treaty ceilings on dividends, interest, royalties
• Pensions: Portugal, unless it taxes them at less than the ordinary rate — the clause that caught NHR residents

Income tax, side by side

A Dutch employee on 60 000 € pays about 21 800 € in box 1 before credits (roughly 16 000 € after the general and labour credits); the same salary in Portugal costs about 15 400 € of IRS plus 6 600 € of contributions. Retirees: Dutch pensioners pay 17,85 % on the first 38 883 € then 37,56 %; Portugal taxes the pension after 4 587 € at the progressive rates. The personal income page works the examples.

The 1999 convention

• Dividends, interest, royalties: 10 % each at source. Dutch dividend withholding is 15 % under domestic law, reduced to 10 % on the treaty form; Portugal’s 28 % falls to 10 % for a Dutch resident.
• Pensions and social security (art. 18): taxable only in the residence state — with a source-state right if three conditions are all met: the contributions were tax-relieved in the source state, the pension is not taxed in the residence state at the ordinary rate for employment income (or less than 90 % of it is taxed), and the pensioner’s total pensions exceed 10 000 € in the year. That clause let the Netherlands tax the Dutch pensions of NHR residents; a Dutch pension taxed in Portugal at the full progressive rates does not meet the second condition, so the Netherlands must exempt it. Lump sums taken before the pension starts may be taxed at source.
• Government service (art. 19): ABP pensions for public employment stay Dutch unless the pensioner is resident and national of Portugal.
• Property: where it stands. Gains on shares: residence state.
• Relief: the Netherlands exempts with progression most Portuguese-source income it may not tax and credits withholding; Portugal credits Dutch tax.

Leaving the Netherlands with a BV

A shareholder of 5 % or more who emigrates receives a conservative assessment (conserverende aanslag) on the deemed box 2 gain at departure; payment is deferred for a move within the EU and the assessment lapses only in limited cases, so a later sale or dividend in Portugal can trigger the Dutch tax on the pre-departure value. The same mechanism applies to pension entitlements and annuities with tax-relieved premiums. Portugal then taxes dividends and gains at 28 % from the original cost, with credit only for tax the treaty allows the Netherlands to charge (10 % on dividends). This is the item to plan before deregistering — see corporate tax.

Companies and VAT

Social security

Both countries apply the EU coordination rules (one system at a time, A1 postings up to 24 months, pension periods combined). Dutch employees pay 27,65 % national insurance inside the first bracket plus the Zvw health contribution; employers pay unemployment (2,74 % on permanent contracts, 7,74 % otherwise), disability (6,27 % to 7,63 %) and the 6,10 % health levy up to a ceiling of 79 409 €. Portugal: 11 % employee and 23,75 % employer with no ceiling. The social security page sets them side by side, with the AOW rules for emigrants.

Property and inheritance

IMT by bracket plus 0,8 % stamp duty on purchase (7,5 % flat while you are still non-resident since 25 May 2026, refundable within two years of becoming resident), IMI at 0,3–0,45 % of the tax value, AIMI above 600 000 €; the Netherlands charges 2 % transfer tax on a home you will live in (0 % for buyers under 35 below a price ceiling), 10,4 % on other property, and the annual OZB. No Dutch inheritance tax reaches a Portuguese resident’s estate after ten years abroad (Dutch nationals stay liable for ten years after emigration); Portugal charges 10 % stamp duty with spouses, children and parents exempt.

Special regimes

NHR closed on 1 January 2024. IFICI gives 20 % for ten years on Portuguese income from listed activities and exempts foreign income with progression — with the Dutch pension clause in mind: pensions are excluded from IFICI and taxed in full, which is what keeps them Portuguese. The tax incentives page compares IFICI with the Dutch expat ruling and the innovation box.

Before you move

Questions from Dutch clients