The forms that matter
| Portugal | Norway | |
|---|---|---|
| Sole trader | empresário em nome individual or freelance activity opened at Finanças in minutes, no capital, unlimited liability; simplified tax regime up to 200 000 € of turnover | enkeltpersonforetak (ENK) registered with the Brønnøysund registers — NOK 2 181 in the Central Coordinating Register, NOK 3 883 if also in the Register of Business Enterprises — no capital, unlimited liability |
| Private limited company | Lda (sociedade por quotas): capital freely fixed, each quota at least 1 € (CSC art. 201.º, 219.º); one partner possible (unipessoal); formed in one session at Empresa na Hora for 360 € with a pre-approved name and standard articles | AS (aksjeselskap): minimum share capital NOK 30 000 (Companies Act § 3-1), paid before registration; registration fee NOK 6 825 online; a board of at least one member (§ 6-1); audit can be waived by small companies within thresholds of turnover, assets and ten employees (§ 7-6) |
| Public company | SA: minimum capital 50 000 € (CSC art. 276.º), board and supervisory bodies | ASA: for listed and large companies, higher capital and stricter governance |
| Branch of a foreign company | registration of a permanent representation with the commercial registry and a NIPC | NUF (Norwegian-registered foreign enterprise) at Brønnøysund |
| Beneficial owners | declared to the RCBE (Lei n.º 89/2017) at incorporation and on every change | declared to the Register of Beneficial Owners at Brønnøysund |
A Norwegian who moves a consulting or IT activity to Portugal usually starts as a freelancer under the simplified regime and incorporates an Lda when turnover or liability justifies it; a Norwegian AS that wants a Portuguese arm chooses between a subsidiary Lda (its own tax residence, 19 % IRC, dividends up to the parent under the treaty) and a branch (taxed in Portugal on the branch profit only).
- 1 € vs NOK 30 000 — minimum capital of an Lda and an AS
- 360 € vs NOK 6 825 — cost of forming a company at Empresa na Hora and at Brønnøysund
- 19 % vs 22 % corporate tax in 2026; 15 % on a Portuguese SME's first 50 000 € of profit
- Twelve months — a building site becomes a permanent establishment under the treaty
Running the company
Portugal: every company must keep organised accounts under the national standard (CIRC art. 123.º), with no backlog beyond 90 days, and file monthly SAF-T invoicing data, VAT returns (monthly above 650 000 € of turnover, quarterly below), the annual IRC return (Modelo 22) by 31 May and the simplified corporate information (IES) by 15 July; payroll contributions of 23,75 % employer and 11 % employee are declared monthly to Social Security. Directors (gerentes) are subsidiarily liable for the company’s tax and social-security debts when the company cannot pay and the debt fell due during their management (Lei Geral Tributária, art. 24.º), a rule that surprises Norwegian owners used to the AS shield.
Norway: annual accounts filed with the Brønnøysund registers, employer contributions of 14,1 % in zone 1, and a duty for the board to act when equity becomes inadequate (Companies Act § 3-4 and § 3-5).
Tax at company and owner level
| Portugal | Norway | |
|---|---|---|
| Corporate income tax | 19 % in 2026, 18 % in 2027, 17 % from 2028; 15 % on the first 50 000 € for SMEs; municipal surcharge up to 1,5 %; state surcharge above 1,5 million € | 22 % |
| Dividends to a resident individual owner | 28 % flat (or the brackets) | 22 % on the dividend grossed up by 1,72 — 37,84 % effective |
| Dividends across the border | treaty: 5 % when a company holds 10 % for twelve months, 15 % otherwise; 0 % under the Portuguese participation exemption for an EEA parent holding 10 % for a year (CIRC art. 14.º n.º 3) | treaty: 5 % to a Portuguese company holding 10 % for twelve months, 15 % otherwise |
| Owner’s social contributions | manager (gerente) with salary: 11 % + 23,75 % on the salary | national insurance 7,6 % on salary; 10,8 % on business income of a sole trader |
The Portugal vs Norway corporate tax page works through the numbers, including the wealth tax that a Norwegian resident owner pays on the company’s shares and a Portuguese resident does not.
The treaty and where the company is taxed
Under the 2011 convention a Portuguese company is taxed in Norway only on profits of a permanent establishment there — a fixed place of business, a building site lasting more than twelve months, or a dependent agent — and vice versa; work on the Norwegian continental shelf has its own article with shorter thresholds. A Norwegian AS whose sole director now lives and works from Portugal risks Portuguese tax residence through effective management, or at least a Portuguese permanent establishment, which is why the move of an owner is a corporate question as much as a personal one.
Steps
Choose the vehicle
Freelance activity, Lda, branch of the AS, or a new AS-owned Lda; the answer depends on liability, clients' expectations and the dividend route.
NIF and NIPC
Personal tax numbers for the partners, then the company's NIPC at Empresa na Hora; Norwegian corporate documents apostilled for a branch.
Accountant and bank
Certified accountant appointed at incorporation; bank account with the capital; certified invoicing software before the first invoice.
Norwegian side
Exit or continuation of the AS assessed with Norwegian counsel; exit tax on shares if the owner emigrates; A1 certificates for staff posted to Portugal.
We incorporate and run Portuguese companies for Norwegian founders — Empresa na Hora, accounting, VAT, payroll, the annual returns — and coordinate with your Norwegian accountant on the group and the treaty. Ask for a formation quote.
Questions
Can my Norwegian AS simply invoice Portuguese clients from Norway?
Yes, without Portuguese corporate tax, as long as it has no permanent establishment here — no office, no site over twelve months, no agent concluding contracts. Once you personally work from Portugal for the AS, that changes.
Do I need a Portuguese resident director?
No. Portuguese law does not require a resident director; it requires a certified accountant and a Portuguese address for the seat. Effective management from abroad is a tax question, not a company-law one.
Is the 1 € capital of an Lda taken seriously by banks and clients?
Legally yes; commercially most founders put in a few thousand euros to fund the start and reassure suppliers and banks, which look at the capital and the partners' guarantees rather than the legal minimum.
Sources and official references
- Código das Sociedades Comerciais — artigo 201.º (capital freely fixed), 219.º n.º 3 (quota of at least 1 €), 276.º n.º 5 (SA minimum capital 50 000 €) — checked 19.9.2026
- Justiça.gov.pt — Empresa na Hora: company formed in one session, 360 € — checked 19.9.2026
- Lei n.º 89/2017 — Registo Central do Beneficiário Efetivo — checked 19.9.2026
- Código do IRC, artigo 123.º — organised accounting, no backlog beyond 90 days; artigo 120.º–121.º — Modelo 22 by 31 May, IES by 15 July — checked 19.9.2026
- Lei Geral Tributária, artigo 24.º — subsidiary liability of directors and managers for tax debts — checked 19.9.2026
- Lei n.º 64/2025 — IRC 19 % in 2026, 18 % in 2027, 17 % from 2028; 15 % on the first 50 000 € for SMEs — checked 19.9.2026
- Código do IRC, artigo 14.º n.º 3 — dividends to an EU/EEA parent holding 10 % for one year exempt from withholding — checked 19.9.2026
- Código do IVA, artigo 41.º — monthly returns above 650 000 €, quarterly below — checked 19.9.2026
- Lei n.º 110/2009 (Código Contributivo), artigo 53.º — 23,75 % employer, 11 % employee — checked 19.9.2026
- Lovdata — Aksjeloven § 3-1 (NOK 30 000), § 3-4 and § 3-5 (adequate equity and duty to act), § 6-1 (board of one or more members), § 7-6 (waiver of audit within thresholds) — checked 19.9.2026
- Brønnøysundregistrene — registration fees: limited company NOK 6 825 online; sole proprietorship NOK 2 181 or 3 883 — checked 19.9.2026
- Brønnøysundregistrene — Register of Beneficial Owners — checked 19.9.2026
- Skatteetaten — general income 22 %; dividend adjustment factor 1,72 (37,84 % effective); employer's national insurance 14,1 % zone 1; national insurance 7,6 % / 10,8 % — checked 19.9.2026
- Convenção Portugal–Noruega (2011) — art. 5 permanent establishment (building site twelve months), offshore article, art. 7 business profits, art. 10 dividends 5 % / 15 % — checked 19.9.2026