Residence (art. 4)
Turkey’s domicile or six-month test and Portugal’s 183 days or habitual home can overlap; the treaty settles it by permanent home, then centre of vital interests, then habitual abode, then nationality, then mutual agreement.
- 15 % on dividends, 5 % for a company holding 25 % for two years
- 10 % on interest from loans of more than two years, 15 % otherwise; 10 % on royalties
- Pensions taxable only in the residence state; public-service pensions in the paying state
- 183 days of services in twelve months create a permanent establishment
Income by income
| Income | Taxed in | Source ceiling |
|---|---|---|
| Employment (art. 15) | where the work is done; residence state only if under 183 days and paid by a non-resident employer without a permanent establishment | — |
| Business profits (art. 5, 7) | residence state unless a permanent establishment: fixed place, building site over a set period, dependent agent, or services rendered in the other state for more than 183 days in twelve months | — |
| Dividends (art. 10) | both; source limited | 15 %; 5 % for a 25 % corporate holding kept two years |
| Interest (art. 11) | both; source limited | 10 % for loans over two years; 15 % otherwise |
| Royalties (art. 12) | both; source limited | 10 % |
| Rents and gains on property (art. 6, 13) | where the property is | — |
| Gains on shares and other assets (art. 13) | residence state | — |
| Pensions for past employment (art. 18) | residence state only | — |
| Public-service salaries and pensions (art. 19) | the paying state, unless the recipient is resident and national of the other | — |
| Other income | residence state | — |
Pensions in practice
A Turkish resident of Portugal declares SGK and private pensions in Portugal at the progressive rates after the 4 587 € deduction; Turkey does not tax them under article 18. A pension for service to the Turkish state stays Turkish and is exempt here with progression, unless the pensioner is a Portuguese national living here.
Relief (art. 22)
Both countries apply the credit method: Portugal deducts the Turkish tax on income the treaty lets Turkey tax, up to the Portuguese tax on that income and up to the treaty rate (IRS Code, art. 81.º); Turkey credits Portuguese tax on Portuguese-source income of its residents.
Using the treaty
Residence certificate
From Finanças online for Turkish payers; from the Turkish tax office for Portuguese-source income of a Turkish resident.
Reduced withholding
Portugal: Modelo 21-RFI to the payer. Turkey: the certificate presented to the payer or a refund claim under the treaty.
Declare at home
Portuguese annex J with each Turkish item, converted to euros at the payment date, and the Turkish tax within the treaty rate.
Disputes
Mutual agreement procedure through the residence state's competent authority.
We obtain the certificates, file the Portuguese treaty forms and compute the credit; Turkish-side filings go through your Turkish adviser. Ask about your case.
Questions
My Turkish company pays me dividends after I move. What is withheld?
Turkey withholds at its decree rate and reduces it to the treaty 15 % on your Portuguese residence certificate (or refunds the excess); Portugal charges 28 % and credits the 15 %.
Does the treaty cover Turkish inheritance and gift tax?
No; it covers income taxes. Turkish inheritance and gift tax applies under Turkish law to Turkish assets and Turkish-domiciled persons; Portugal charges 10 % stamp duty on Portuguese assets passing outside the direct line.
I consult for Turkish clients from Lisbon. Is the income Turkish-source?
Not unless you have a fixed base or spend more than 183 days in Turkey in twelve months rendering the services there. Work done from Portugal is taxed in Portugal only.
Sources and official references
- Diário da República, 21 February 2006 — Convention between Portugal and Turkey (Res. AR 13/2006): art. 4, 5, 10, 11, 12, 13, 15, 18, 19, 22 — checked 18.9.2026
- Autoridade Tributária — treaty table 2026: Turkey (in force 18.12.2006; dividends 5 % m) / 15 %; interest 10 % t) / 15 %; royalties 10 %) — checked 18.9.2026
- Código do IRS, artigo 81.º — foreign tax credit within the treaty limits — checked 18.9.2026