The rates
| Portugal | Netherlands | |
|---|---|---|
| First bracket | 15 % on the first 50 000 € (SMEs); otherwise 19 % | 19 % on the first 200 000 € |
| Above | 19 % in 2026, 18 % in 2027, 17 % from 2028 | 25,8 % |
| Local | municipal surcharge (derrama) up to 1,5 % | — |
| Large profits | state surcharge 3 % above 1,5 million, 5 % above 7,5 million, 9 % above 35 million | — |
| Innovation | patent box: 85 % of qualifying income exempt; SIFIDE and RFAI credits | innovation box: 9 % effective rate on qualifying profit; WBSO payroll credit |
| Profit of 150 000 €, SME | 15 % × 50 000 + 19 % × 100 000 + derrama ≈ 28 800 € (19,2 %) | 19 % × 150 000 = 28 500 € (19 %) |
| Profit of 500 000 € | ≈ 100 000 € (20 %) with derrama | 19 % × 200 000 + 25,8 % × 300 000 = 115 400 € (23,1 %) |
Below 200 000 € the two systems charge almost the same; above it Portugal pulls ahead by four to six points, and by more from 2028.
- 19 % vs 19 % first-bracket rates; 17 % vs 25,8 % top rates from 2028
- 28 % vs 24,5–31 % on dividends to the owner (box 2 in the Netherlands)
- 10 % treaty withholding on cross-border dividends
- Conservative assessment when a 5 % shareholder leaves the Netherlands
The owner’s tax
| Portugal | Netherlands | |
|---|---|---|
| Dividends to the owner | 28 % flat | box 2: 24,5 % to 68 843 €, 31 % above |
| Sale of the shares | 28 % (50 % of the gain for micro and small companies) | box 2: same rates on the gain |
| Director’s salary | progressive 12,5–48 %; contributions 11 % + 23,75 % on at least the IAS | box 1 progressive; the customary-salary rule (gebruikelijk loon) sets a minimum director’s pay each year |
| All-in on 100 000 € distributed | 18 500 € IRC + derrama, then 28 % of 81 500 € → 58 700 € net | 19 000 € VPB, then 24,5 % on 68 843 € and 31 % on the rest → about 58 000 € net |
Almost identical at that level; Portugal’s advantage grows with profit because its corporate rate keeps falling and its dividend rate is flat.
Moving a BV’s director to Portugal
- Corporate residence. A BV managed from Portugal has its effective management here; the treaty (art. 4) makes it Portuguese-resident and Portugal taxes its worldwide profit. The Netherlands keeps a claim under its incorporation rule for some purposes (dividend tax), which the treaty overrides for the company’s own profits. Appointing Dutch management and holding board meetings in the Netherlands keeps the BV Dutch; most owner-managers instead accept Portuguese residence or set up a Portuguese company.
- Conservative assessment. On emigration a 5 % shareholder is assessed on the deemed box 2 gain (market value less acquisition cost) with payment deferred; dividends and sales after departure can call in the deferred tax. Portugal then taxes the actual dividends and gains at 28 % from the original cost, crediting the 10 % treaty withholding on dividends but nothing for the deferred Dutch assessment.
- Substance. Registered office, a Portuguese accountant, board decisions taken in Portugal and the director’s residence here are what Finanças and the Belastingdienst both look at.
VAT and compliance
| Portugal | Netherlands | |
|---|---|---|
| VAT | 23 / 13 / 6 % | 21 / 9 / 0 % |
| Small businesses | exempt up to 15 000 € of turnover | KOR exemption up to 20 000 € |
| Returns | monthly above 650 000 € of turnover, otherwise quarterly, by the 20th of the second month | quarterly for most, monthly for larger businesses |
| Corporate return | Modelo 22 by 31 May; IES by 15 July | within five months of year end (extension through an adviser) |
| Invoicing | certified software, SAF-T monthly, e-invoicing being phased in | free format; e-invoicing for public bodies |
Setting up here
NIF and NIPC
Founder's tax number (through a representative if abroad) and the company's at incorporation.
Lda or unipessoal
Incorporated online or at Empresa na Hora with capital from 1 €; a certified accountant is appointed from the start.
Registrations
Activity and VAT regime at Finanças, Segurança Social for company and director, beneficial-owner register, bank account.
Running it
Monthly payroll and withholding, VAT returns, the Modelo 22 in May, dividends after approval of the accounts.
Access Portugal incorporates the Lda, keeps the books, files IRC, VAT and payroll, and coordinates with your Dutch adviser on the BV's exit and the conservative assessment. Ask for a set-up quote.
Questions
Should I keep the BV or open a Portuguese Lda?
If the business is Dutch (clients, staff, premises) keep the BV with Dutch management and pay yourself from Portugal under the treaty. If you are the business and you live here, the BV becomes Portuguese-resident anyway; a Lda is simpler and avoids two sets of filings. The conservative assessment on the BV shares is computed either way.
Is the Dutch 15 % dividend tax refundable in Portugal?
The treaty caps it at 10 %; the 5 % excess is reclaimed from the Belastingdienst, and the 10 % is credited against the Portuguese 28 %.
Does Portugal have a customary-salary rule for directors?
No minimum salary for tax purposes, but social security contributions for a director are computed on at least the IAS (537,13 € a month) and Finanças expects remuneration in line with the work performed when profits are large.
Sources and official references
- Belastingdienst — Tarieven vennootschapsbelasting: 19 % to 200 000 €, 25,8 % above — checked 18.9.2026
- Belastingdienst — Box 2 tarieven 2026: 24,5 % to 68 843 €, 31 % above — checked 18.9.2026
- Belastingdienst — BTW rates 21 %, 9 %, 0 % — checked 18.9.2026
- Lei n.º 64/2025 — IRC 19 % (2026), 18 % (2027), 17 % (2028); 15 % on the first 50 000 € for SMEs — checked 18.9.2026
- Código do IRC, artigo 87.º-A — state surcharge; artigo 120.º — Modelo 22 by 31 May — checked 18.9.2026
- Convention Portugal–Netherlands — art. 4 (effective management), art. 10 (dividends 10 %), art. 13 (gains) — checked 18.9.2026