Residence: days on both sides
Ireland counts days: 183 in the year, or 280 over two years with at least 30 in each. Portugal counts 183 days in any twelve-month window, or the day you keep a home that looks like a habitual residence (IRS Code, art. 16.º). Ireland also keeps a third status — ordinary residence — for three years after you leave, during which Irish tax still reaches most foreign income above 3 810 €; the treaty tie-breaker (permanent home, centre of vital interests, habitual abode, nationality) resolves the overlap in Portugal’s favour for anyone who has genuinely moved.
- 20 % / 40 % Irish bands (44 000 € single, 53 000 € married) plus USC up to 8 %; 12,5 % to 48 % in Portugal
- 33 % Irish CGT, CAT and DIRT; 28 % Portuguese flat rate, no tax between spouses, children and parents on inheritances
- Pensions taxed in Portugal under article 18 — except Irish public-service pensions
- 15 % / 15 % / 10 % treaty ceilings on dividends, interest, royalties
Income tax, side by side
| Portugal 2026 | Ireland 2026 | |
|---|---|---|
| Tax-free | 4 587 € deduction on salaries and pensions | personal credit 2 000 € (4 000 € married) plus the employee or earned-income credit 2 000 € |
| Bands | nine brackets, 12,5 % to 48 % (48 % above 86 634 €) | 20 % to 44 000 € (single) or 53 000 € (married, up to 88 000 € with two incomes); 40 % above |
| Surcharges | solidarity 2,5 % above 80 000 €, 5 % above 250 000 € | USC 0,5 % to 12 012 €, 2 % to 28 700 €, 3 % to 70 044 €, 8 % above (11 % on self-employed income above 100 000 €) |
| Social insurance | 11 % employee, 23,75 % employer, no ceiling | PRSI 4,2 % employee, 11,25 % employer |
| Capital income | 28 % flat | DIRT 33 % on deposit interest; dividends at marginal rates; Irish and EU funds 38 % exit tax |
| Capital gains | 28 % on securities (less after 2/5/8 years); half of a property gain at progressive rates | 33 % after 1 270 € |
| Couples | joint filing, income split | joint assessment with transferable band |
Ireland’s marginal rate of 40 % + 8 % USC + 4,2 % PRSI = 52,2 % applies from about 70 000 €; Portugal’s 48 % from 86 634 €, with 11 % contributions on top. Between 44 000 € and 70 000 € Ireland charges 40 % + 3 % + 4,2 % where Portugal charges 34,9 % to 44,6 % + 11 %. The two systems are closer than their reputations: Portugal is lighter for a single high earner, Ireland lighter on modest salaries thanks to the credits. Detail and examples on the personal income tax page.
The 1993 convention
- Pensions (art. 18): pensions for past employment and annuities are taxable only in the residence state — an Irish occupational or personal pension and, in practice, the State Pension are taxed in Portugal once you live here, and Revenue stops PAYE on a PAYE exclusion order. Public-service pensions (art. 19) — civil service, HSE, teachers, Garda — stay taxable only in Ireland unless you are a Portuguese national resident here.
- Dividends: 15 %. Irish domestic law does not withhold on dividends paid to residents of treaty countries who file the exemption form, so the Portuguese 28 % (or 15 %) is the only tax in practice; Portuguese dividends to an Irish resident: 15 % here, taxed in Ireland with credit. Interest: 15 %. Royalties: 10 %.
- Property: rents and gains taxed where the property is; the residence state credits.
- Gains on shares: residence state only.
- Relief: credit in both countries. Details on the treaty page.
Companies
Ireland’s 12,5 % on trading income (15 % for groups above 750 million euros under Pillar Two, 25 % on passive income) against Portugal’s 19 % in 2026 falling to 17 % in 2028, with 15 % on the first 50 000 € for SMEs — see corporate tax. VAT: 23 / 13,5 / 9 / 4,8 % in Ireland, 23 / 13 / 6 % in Portugal.
Property, inheritance, funds
- Buying in Portugal: IMT by bracket (0 % to 106 346 € on a main home, up to 8 %; 7,5 % flat while you are still non-resident since 25 May 2026, refundable within two years of becoming resident) plus 0,8 % stamp duty. Ireland: stamp duty 1 % to 1 million, 2 % to 1,5 million, 6 % above.
- Owning: IMI 0,3–0,45 % of the tax value and AIMI above 600 000 €, against Ireland’s Local Property Tax of 0,0906 % to 0,3 % by band.
- Inheritance: Portugal 10 % stamp duty, spouses, children and parents exempt; Ireland CAT at 33 % above 400 000 € from a parent, 40 000 € from other relatives, 20 000 € from anyone else.
- Funds: Ireland’s 38 % exit tax on Irish and EU UCITS every eight years has no Portuguese counterpart — Portugal taxes distributions and gains at 28 % when they happen, less after two, five or eight years of holding.
Special regimes
NHR closed on 1 January 2024. IFICI gives 20 % for ten years on Portuguese income from listed activities — research, certified start-ups, qualified posts in exporting or recognised companies — and exempts foreign income (with progression) for people not resident here in the previous five years. Pensions are excluded. Ireland’s SARP, in the other direction, relieves inbound executives and is irrelevant once you leave.
Before you move
Crystallise or hold
Irish CGT at 33 % on shares sold before departure against 28 % (less after two years) in Portugal; Irish funds are better sold before the move to end the 38 % regime.
Leave properly
Split-year treatment claimed in Ireland; PAYE exclusion order for pensions; Form 12 or 11 for the year of departure.
Register in Portugal
NIF, address at Finanças, NISS, health centre; S1 from the Department of Social Protection for State Pension recipients.
First Portuguese return
April–June of the following year with annex J for Irish income and the treaty credits.
Access Portugal's accountants handle the Portuguese side — registration, IFICI, the annual return with Irish pensions and dividends — and coordinate the PAYE exclusion order and the Irish exit with your Irish adviser. Book a first consultation.
Questions from Irish clients
Is my Irish State Pension taxed in Portugal?
Yes, once you are resident: the treaty gives Portugal the right over pensions, and Revenue does not tax the State Pension of a non-resident under the treaty. It is declared in annex J and taxed with your other income after the 4 587 € deduction. A HSE or civil-service pension stays Irish.
What happens to my ARF?
Distributions from an Approved Retirement Fund are pension income under the treaty — taxed in Portugal at the progressive rates, with Irish PAYE stopped on an exclusion order. The imputed 4 % or 5 % distribution rule continues to apply in Ireland but produces no Irish tax once the exclusion order is in place.
Do I still pay Irish CAT if I inherit from my parents in Ireland?
Yes: CAT applies when the disponer or the beneficiary is Irish-resident or the asset is Irish. A Portuguese resident inheriting an Irish house from an Irish-resident parent pays 33 % above the 400 000 € threshold in Ireland and nothing in Portugal.
Sources and official references
- Revenue — Double Taxation Treaty between Ireland and the Portuguese Republic (1993; protocol 2005): art. 10–13, 18 (pensions: residence state), 19 (government pensions), explanatory notes — checked 18.9.2026
- Autoridade Tributária — treaty table 2026: Ireland (in force 11.7.1994; protocol 18.12.2006; dividends 15 %, interest 15 %, royalties 10 %) — checked 18.9.2026
- Revenue — tax rates, bands and reliefs 2026: 20 % to 44 000 € (53 000 € married), 40 % above; personal credit 2 000 € — checked 18.9.2026
- Revenue — Budget 2026 summary: USC 0,5 % / 2 % / 3 % / 8 %; fund and life-policy exit tax cut from 41 % to 38 % — checked 18.9.2026
- Revenue — Capital Gains Tax: 33 %, 1 270 € annual exemption — checked 18.9.2026
- Revenue — CAT group thresholds (400 000 € / 40 000 € / 20 000 €) and rate 33 % — checked 18.9.2026
- Revenue — Corporation Tax basis of charge: 12,5 % on trading income — checked 18.9.2026
- Revenue — current VAT rates from 1 January 2026: 23 %, 13,5 %, 9 %, 4,8 % — checked 18.9.2026
- Department of Social Protection — PRSI advance notice 2026: employee 4,20 %, employer 11,25 % — checked 18.9.2026
- Código do IRS, artigo 68.º — Portuguese brackets 2026; artigo 16.º — residence — checked 18.9.2026