XJuly 23, 2026
Portugal can tax you personally on the whole profit of a foreign company you hold 25 percent of, with nothing distributed.
Proving that company has real staff and premises is no defence. That carve-out is EU and EEA only.
These are CFC rules. People pick the company's jurisdiction and stop there. Attribution lands on the shareholder, not the company.
Article 66 of the Portuguese corporate income tax code, extended to individuals by the personal one, catches a holding of at least 25 percent, aggregated across related parties, once its effective tax abroad falls under half of the Portuguese charge. Then the full profit is imputed pro rata. Not the passive slice, all of it.
Outside that zone the way out is not substance. It is a separate gate. Keep the six listed income categories at or below 25 percent of total income and the article never applies.
The architecture differs more than the numbers.
United States: 10 percent each, once US holders together pass 50 percent, and it tracks citizenship as well as residence
Portugal: 25 percent, related parties counted in
New Zealand: CFC at 40 percent for a single resident if no non-associated non-resident holds more, attribution to you at a 10 percent income interest
One more line a consultant should read twice. An active company escapes on the under 5 percent attributable income test, but income the Act counts as personal services is attributed anyway.
Elsewhere the charge never reaches an individual. Bulgaria, Czech Republic and Ireland bind corporate shareholders only, though Ireland's transfer of assets abroad rules reach individuals. Hong Kong, Georgia, Jersey and Isle of Man run no CFC regime at all.
The company's jurisdiction sets the corporate rate. Where you are taxed as a person decides if it survives.
If you moved the company before you moved yourself, which of the two is setting your bill this year?
Data from GeoCompass, the jurisdiction intelligence layer I build at Lucky Nomads.
Bulgaria
Czech Republic
Georgia
Hong Kong
Ireland
Isle of Man
Jersey
New Zealand
Portugal
United States