How the vacuum works
Without a convention there is no tie-breaker, no source-state ceiling and no obligation on either state to relieve the other’s tax. What remains:
- Each country’s residence rules apply in full; dual residence is possible and unrelieved.
- Each country taxes its own source income of non-residents at its domestic rates.
- Portugal grants its residents a unilateral credit for foreign income tax paid on foreign-source income, up to the Portuguese tax on that income (IRS Code, art. 81.º n.º 1). Sweden grants its residents a similar unilateral credit under its own law.
- SINK 22,5 % (20 % from 2027) on Swedish pensions and salaries of non-residents
- 30 % Swedish coupon tax on dividends; 28 % Portuguese withholding on Portuguese dividends to Swedes
- Ten years of Swedish tax on gains from Swedish and Swedish-acquired shares after departure
- Credit capped at the Portuguese tax — the higher of the two taxes is what you pay
Income by income, for a Portuguese resident
| Swedish-source income | Sweden | Portugal | Net effect |
|---|---|---|---|
| Pensions (state, occupational, private) | SINK 22,5 % | progressive rates after 4 587 €, credit for the Swedish tax | the higher of the two |
| Salary for work done in Sweden | SINK 22,5 % | progressive rates, credit | the higher of the two |
| Salary for work done in Portugal, paid by a Swedish employer | not Swedish-source: no SINK | full Portuguese tax and contributions | Portuguese only |
| Dividends from Swedish companies | coupon tax 30 % | 28 %, credit capped at 28 % | 30 % |
| Interest from Swedish banks | not taxed for non-residents | 28 % | 28 % |
| Gains on Swedish shares within ten years of leaving | 30 % | 28 %, credit capped at 28 % | 30 % |
| Gains on Swedish shares after ten years, or on funds | none | 28 % | 28 % |
| Rent and gains on Swedish property | Swedish tax (30 % on the net; 22 % effective on gains from a home) | 25 % on rents or progressive; half the gain at progressive rates; credit | roughly the higher |
| Business profits of a Swedish permanent establishment | Swedish tax | Portuguese tax with credit | the higher |
For a Swedish resident with Portuguese income the mirror applies: 25 % / 28 % Portuguese withholding under art. 71.º, Portuguese tax on Portuguese property, and a Swedish credit.
Residence without a tie-breaker
Sweden treats a person as resident when they live there, stay there habitually (six months) or keep an essential connection — a home, a family, a business, a Swedish citizenship combined with other ties — with a five-year presumption for Swedish citizens and long-term residents. Portugal treats a person as resident after 183 days or from the day a habitual home is kept. Someone who meets both tests is taxed by both on worldwide income, and only the Portuguese credit (and the Swedish one) soften it. The practical rule for Swedes: end the Swedish connection cleanly before claiming Portuguese residence.
Companies
No treaty means no reduced withholding, but EU law still applies: dividends between EU parent and subsidiary companies (10 % held for a year) are exempt on both sides; interest and royalties between associated EU companies likewise. A Swedish company’s Portuguese permanent establishment is defined by Portuguese domestic law (IRC Code, art. 5.º), which is broader than a treaty definition — a building site of more than six months, dependent agents, some service activities.
Steps
Residence
Deregistration from the Swedish population register, evidence that the essential connection has ended, Portuguese registration at Finanças.
SINK application
To Skatteverket for each Swedish payer; the alternative — ordinary taxation with allowances — is available when 90 % of income is Swedish.
Coupon tax
30 % withheld at source; no reclaim available without a treaty.
Portuguese return
Annex J with the gross Swedish income and the Swedish tax; the credit is computed per income category, and any excess is lost.
We compute the unilateral credits correctly — category by category, capped, without the treaty rates that no longer exist — and coordinate the SINK and ten-year-rule questions with your Swedish adviser. Ask about your situation.
Questions
Can I still claim the old 2002 treaty for income earned before 2022?
Only for income of 2021 and earlier. Since 1 January 2022 the convention has no effect in either country.
Is Portuguese tax on my Swedish pension refunded because Sweden taxed it first?
No. Portugal deducts the Swedish tax from the Portuguese tax on the pension; if the Swedish tax is higher, the Portuguese tax is zero and nothing is refunded; if lower, you pay the difference.
Does the absence of a treaty affect social security?
No. Social security coordination is an EU matter (Regulation 883/2004): one system at a time, A1 certificates, pension periods combined, S1 health cover — unchanged by the denunciation.
Sources and official references
- Autoridade Tributária — treaty table 2026, note aa): convention with Sweden ceased to apply on 1.1.2022 (Aviso n.º 2/2022 of the Foreign Ministry) — checked 18.9.2026
- Skatteverket — living abroad with property and capital income in Sweden: coupon tax on dividends, ten-year rule on shares, property income — checked 18.9.2026
- Skatteverket — 2026: SINK 22,5 %; capital income 30 %; corporate 20,6 % — checked 18.9.2026
- Código do IRS, artigo 81.º — unilateral credit for foreign tax (n.º 1), limited to the Portuguese tax on the income; n.º 2 applies only where a treaty exists — checked 18.9.2026
- Código do IRS, artigo 71.º — 25 % / 28 % final withholding on Portuguese-source income of non-residents — checked 18.9.2026