The rates
| Portugal | Turkey | |
|---|---|---|
| Corporate tax | 19 % in 2026, 18 % in 2027, 17 % from 2028 | 25 % (30 % for banks, insurers and other financial companies) |
| Small companies | 15 % on the first 50 000 € of taxable profit (EU SME definition) | no reduced rate |
| Surcharges | derrama up to 1,5 %; state surcharge 3 / 5 / 9 % above 1,5 / 7,5 / 35 million | domestic minimum corporate tax rules apply from 2025 |
| Dividends to the parent | 28 % (25 % to companies) reduced to 5 % for a Turkish company holding 25 % for two years, 15 % otherwise | withholding at the decree rate, reduced to 5 % / 15 % under the treaty for a Portuguese shareholder |
| VAT | 23 / 13 / 6 % | 20 / 10 / 1 % |
| Employer contributions | 23,75 % of salary | SGK premiums with employer incentives set by decree |
| Filing | Modelo 22 by 31 May; IES by 15 July | annual return by the end of April; quarterly advance tax |
A Portuguese SME making 100 000 € pays about 18 500 € (15 % on 50 000, 19 % on 50 000, 1,5 % derrama); a Turkish company 25 000 €. Distributing the remainder to a Turkish parent costs 5 % Portuguese withholding under the treaty once the 25 % holding has been kept two years.
- 19 % → 17 % vs 25 %
- 15 % on the first 50 000 € for SMEs
- 5 % treaty withholding on dividends to a Turkish parent (25 % for two years); 15 % otherwise
- 183 days of services in Portugal create a permanent establishment for a Turkish company
Subsidiary, branch or nothing
- Subsidiary (Lda): Portuguese IRC; dividends to Turkey at 5 % under the treaty (the EU parent-subsidiary exemption does not apply to a Turkish parent); Turkey credits the Portuguese tax under its own rules.
- Branch: a permanent establishment under article 5 — fixed place of business, building site, dependent agent, or services rendered in Portugal for more than 183 days in twelve months — taxed here on attributable profit.
- Selling into Portugal from Turkey: no IRC without a permanent establishment; VAT on imports at the border and reverse charge on services to Portuguese businesses; Turkey is outside the EU customs union for services, inside it for most industrial goods.
Substance and the D2 founder
A Turkish founder who obtains a D2 visa through a Portuguese company will live here and manage it here — which makes the company Portuguese-resident in substance, and may make any Turkish holding company effectively managed from Portugal as well. The treaty’s tie-breaker for companies looks at effective management. Keep Turkish companies managed in Turkey, with local directors and board meetings, if they are to stay Turkish.
Incentives
RFAI (tax 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 85 % patent box, contractual incentives with AICEP above 3 million euros, and IFICI for Turkish 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. Detail on the tax incentives page.
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, beneficial-owner register, transfer-pricing documentation for dealings with Turkish group companies.
Steps
NIFs and structure
Portuguese tax numbers for the Turkish founders through a representative; subsidiary or branch decided on the business plan and the visa route.
Incorporation
Lda at Empresa na Hora or online with capital from 1 €; apostilled Turkish documents for a branch or a corporate shareholder.
Registrations
Finanças (activity, VAT), Segurança Social, bank account, beneficial owners, certified accountant.
First year
Payroll, VAT, Modelo 22 in May; the D2 file uses the company's registration and accounts.
Access Portugal incorporates the company, runs its accounting, payroll and tax filings, and prepares the D2 visa file on the same documents. Ask for a set-up quote.
Questions
Can a Turkish parent use the EU 0 % on dividends?
No — the parent-subsidiary exemption is for EU/EEA parents. A Turkish company holding 25 % for two years pays the treaty's 5 %; otherwise 15 %.
Is the 15 % SME rate available to a Turkish 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).
Does a D2 visa require a minimum share capital?
No legal minimum: the consulate looks at a credible business plan, funds available in Portugal and, ideally, a company already incorporated. See the D2 visa page for the file.
Sources and official references
- Gelir İdaresi Başkanlığı — corporate tax rates 2025–2026: 25 % general, 30 % for banks and financial institutions — checked 18.9.2026
- Resmî Gazete, 7 July 2023 — Presidential Decision 7346: VAT 20 % and 10 % from 10 July 2023 — 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; artigo 121.º — IES by 15 July — checked 18.9.2026
- Convention Portugal–Turkey — art. 5 (permanent establishment, 183-day services rule), art. 10 (dividends 5 % for 25 % holdings kept two years) — checked 18.9.2026
- Lei n.º 110/2009, artigo 53.º — employer contribution 23,75 % — checked 18.9.2026