The rates
| Portugal | Norway | |
|---|---|---|
| Corporate tax | 19 % in 2026, 18 % in 2027, 17 % from 2028 | 22 % |
| Small companies | 15 % on the first 50 000 € (EU SME definition) | no reduced rate |
| Local and large-profit surcharges | derrama up to 1,5 %; state surcharge 3 % above 1,5 million, 5 % above 7,5 million, 9 % above 35 million | none (petroleum and hydropower have their own regimes) |
| Dividends to the owner | 28 % flat | 37,84 % (22 % on the dividend multiplied by 1,72, after the risk-free “shielding” allowance) |
| Sale of the company’s shares by the owner | 28 % (50 % of the gain for micro and small companies) | 37,84 % |
| Wealth tax on the shares’ value | none | 1,0 % above NOK 1,9 million of net wealth (shares valued at 80 % of their tax value), 1,1 % above 21,5 million |
| Employer social contributions | 23,75 % of salary | 14,1 % in zone 1, lower in the north |
| VAT | 23 / 13 / 6 % | 25 / 15 / 12 % |
A founder who takes 100 000 € of profit out of a Portuguese SME keeps about 58 700 € (15 % on 50 000, 19 % on 50 000, 1,5 % derrama, then 28 %); out of a Norwegian AS about 48 500 € (22 %, then 37,84 % of the rest) — before the wealth tax on the retained value. Payroll runs the other way: 23,75 % here against 14,1 % there, on salaries that are typically well below Norwegian levels.
- 19 % → 17 % vs 22 % corporate rates
- 28 % vs 37,84 % on the owner's dividends and gains
- No wealth tax in Portugal on company shares
- 5 % treaty withholding on dividends to a Norwegian parent holding 10 % for a year; 0 % under the EU/EEA parent-subsidiary rules
Subsidiary, branch or nothing
- Subsidiary (Lda): Portuguese IRC on its profit; dividends to a Norwegian parent holding 10 % for a year are exempt from Portuguese withholding under the EEA parent-subsidiary rules (5 % under the treaty otherwise); Norway’s exemption method for qualifying EEA shareholdings applies on receipt.
- Branch: a permanent establishment under article 5 — a fixed place of business, a building site over twelve months, a dependent agent — taxed here on its attributable profit; Norway credits or exempts under its rules.
- Selling into Portugal from Norway creates no IRC liability without a permanent establishment; VAT follows the import and reverse-charge rules, Norway being outside the EU VAT area.
Incentives
RFAI (credit of up to 30 % of qualifying investment in eligible regions, with IMT and IMI exemptions), SIFIDE (32,5 % of R&D spend plus 50 % of the increase), the patent box (85 % of qualifying income excluded), contractual incentives above 3 million euros negotiated with AICEP, and IFICI for Norwegian staff brought to a qualifying company (20 % personal tax for ten years). Madeira’s International Business Centre offers 5 % to licensed companies creating jobs on the island.
Compliance calendar
Modelo 22 by 31 May, IES by 15 July, VAT monthly (turnover above 650 000 €) or quarterly by the 20th of the second month, monthly payroll withholding and social security, SAF-T invoicing files monthly, beneficial-owner register, transfer-pricing documentation for dealings with the Norwegian parent above the thresholds.
Steps
Structure and NIFs
Subsidiary or branch; Portuguese tax numbers for the Norwegian directors through a representative.
Incorporation
Lda online or at Empresa na Hora with capital from 1 €; branch registered with the parent's apostilled documents.
Registrations
Finanças (activity, VAT), Segurança Social, bank account, beneficial owners, certified accountant.
First year
Payroll and VAT from month one; Modelo 22 the following May; incentive claims where the investment qualifies.
Access Portugal sets up the Portuguese entity, keeps its books and files IRC, VAT and payroll, and prepares the incentive claims, with your Norwegian accountant kept informed. Ask for a set-up quote.
Questions
Does Norway's wealth tax reach a Portuguese company I own?
While you are Norwegian tax resident, yes — worldwide net wealth, shares included. Once you are treaty-resident in Portugal it stops; Portugal has no wealth tax and AIMI applies only to residential property.
Can the 15 % SME rate apply to a Norwegian group's subsidiary?
Only if the group as a whole meets the EU SME definition (fewer than 250 staff and turnover up to 50 million or balance sheet up to 43 million). A small subsidiary of a large group pays 19 %.
How are dividends from my Portuguese Lda taxed if I stay in Norway?
Portugal withholds 5 % under the treaty if a Norwegian company holds 10 % for a year, 15 % for an individual (28 % domestic rate reduced on Modelo 21-RFI); Norway taxes the individual at 37,84 % with credit for the Portuguese withholding.
Sources and official references
- 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; artigo 121.º — IES by 15 July — checked 18.9.2026
- Skatteetaten — general income: 22 % (companies and individuals) — checked 18.9.2026
- Skatteetaten — gains and dividends on shares: 37,84 % effective rate for 2026 (upward adjustment factor 1,72) — checked 18.9.2026
- Skatteetaten — employer's national insurance contributions: 14,1 % in zone 1, regionally differentiated — checked 18.9.2026
- Skatteetaten — wealth tax 2026: 1,0 % above NOK 1,9 million, 1,1 % above 21,5 million — checked 18.9.2026
- Convention Portugal–Norway — art. 5 (permanent establishment, offshore 30-day rule), art. 10 (dividends 5 % for 10 % holdings / 15 %) — checked 18.9.2026