The rates
| Portugal | Belgium | |
|---|---|---|
| Standard rate | 19 % for 2026, 18 % for 2027, 17 % from 2028 (Lei n.º 64/2025) | 25 % since 2020 |
| Small companies | 15 % on the first 50 000 € of taxable profit (SMEs and small mid-caps under the EU definition), standard rate above | 20 % on the first 100 000 € for small companies under the Code des sociétés, on condition — among others — that a director is paid at least 50 000 € |
| Local surcharge | municipal surcharge (derrama) up to 1,5 % of taxable profit, set by each council | none (the former 3 % crisis contribution ended in 2020) |
| Large-profit surcharge | state surcharge 3 % above 1,5 million, 5 % above 7,5 million, 9 % above 35 million | — |
| Effective rate, profit of 100 000 €, SME | 15 % on 50 000 + 19 % on 50 000 + derrama ≈ 18,5 % | 20 % |
| Effective rate, profit of 1 million | ≈ 20,3 % with a 1,5 % derrama | 25 % |
Add the shareholder’s tax to compare take-home: Portugal withholds 28 % on dividends to an individual (25 % to a company, 0 % to an EU parent holding 10 % for a year); Belgium 30 % (with the reduced VVPR-bis rate of 15 % for small companies’ new shares after three years). A Portuguese SME distributing all of a 100 000 € profit leaves its owner about 58 700 €; a Belgian one about 56 000 € at 30 %, or 68 000 € under VVPR-bis.
- 19 % → 17 % Portuguese rate path 2026–2028; 25 % in Belgium
- 15 % on 50 000 € vs 20 % on 100 000 € for small companies
- 28 % vs 30 % on dividends to the owner; treaty ceiling 15 % across the border
- 23,75 % vs 24,92 % employer social contributions on salaries
What else a Belgian founder should compare
- Payroll. Employer contributions are close (23,75 % against 24,92 %), employee contributions lower in Portugal (11 % against 13,07 %). The Portuguese minimum wage is 920 € in 2026, and salaries in technology and services run at roughly half the Belgian level.
- Deductions. Belgium’s notional interest deduction has been phased out; its innovation income deduction (85 % exemption) and investment deduction remain. Portugal offers the RFAI and SIFIDE credits for investment and R&D, a patent-box exemption of 85 % of qualifying income, and the dedução por lucros retidos for reinvested profit.
- Losses. Belgium: carried forward indefinitely, with a basket limit above 1 million euros of profit. Portugal: carried forward indefinitely since 2023, limited to 65 % of each year’s taxable profit.
- Substance. A Portuguese company controlled from Belgium is Belgian-resident if its effective management is there; the treaty (art. 4) looks at the place of effective management. A director living in Lisbon, a Portuguese accountant and board meetings held here are what keep the company Portuguese.
- Compliance. Portugal: Modelo 22 by 31 May, IES by 15 July, monthly or quarterly VAT, monthly payroll withholding, e-invoicing with SAF-T files. Belgium: return seven months after year end, annual accounts to the National Bank, quarterly or monthly VAT.
Setting up in Portugal
Founder's NIF and company NIPC
Through a tax representative if you are abroad; the company can be incorporated by power of attorney.
Incorporation
Empresa na Hora or online, share capital from 1 €, registered office, certified accountant appointed at the start.
Registrations
Start of activity at Finanças (VAT regime), Segurança Social for the company and the director, bank account, beneficial-owner register.
First year
Monthly payroll and withholding, VAT returns, the first Modelo 22 the following May; dividends decided after the accounts are approved.
Access Portugal incorporates the company, keeps the books and files IRC, VAT and payroll — with the director's personal return and the Belgian coordination handled by the same team. Ask for a set-up quote.
Questions
Can my Belgian company simply open a branch in Portugal?
Yes. A branch (sucursal) pays IRC on its Portuguese profit at the same rates, without a separate share capital; the treaty attributes the profit of the permanent establishment to Portugal and Belgium exempts it with progression. A subsidiary is preferred when local contracts, financing or an eventual sale are in view.
Is the 15 % SME band automatic?
It applies to companies that meet the EU SME definition (fewer than 250 staff and turnover up to 50 million or balance sheet up to 43 million) and exercise a commercial, industrial or agricultural activity as their main business. Holding and pure investment companies do not qualify.
What does a director pay in Portugal?
Salary is taxed at the progressive rates (12,5–48 %) with 11 % social contributions on a base of at least the IAS (537,13 € a month); dividends at 28 %. IFICI's 20 % rate can apply to a director of a certified start-up or a qualifying company for ten years.
Sources and official references
- Lei n.º 64/2025, de 7 de novembro — IRC 19 % (2026), 18 % (2027), 17 % (2028); 15 % on the first 50 000 € for SMEs and small mid-caps — checked 18.9.2026
- Código do IRC, artigo 87.º-A — state surcharge 3 % / 5 % / 9 % above 1,5 / 7,5 / 35 million euros — checked 18.9.2026
- Código do IRC, artigo 120.º — Modelo 22 by 31 May; artigo 121.º — IES by 15 July — checked 18.9.2026
- Moniteur belge, 29 December 2017 — Loi du 25 décembre 2017 portant réforme de l'impôt des sociétés (art. 215 CIR 92: 25 %; 20 % on the first 100 000 € for small companies) — checked 18.9.2026
- Autoridade Tributária — treaty table 2026: Belgium (dividends 15 %, interest 15 %, royalties 10 %) — checked 18.9.2026
- ONSS — employer contributions 24,92 % (private sector), employee 13,07 % — checked 18.9.2026