Portuguese resident NHR: Best company location/structure

[toums]

Can i ask you under what section? (since if you put it under capital gains, it would be taxed)

G1 category : More than 365 days holding (tax free)
G category : Less than 365 days holding = 28% tax.

 

[LibertyGuy]

Hey, what about:

1. Property rent from abroad of Portugal under NHR regime - you still pay 0%? Do one need to show to Portugal authorities that they have payed their taxes abroad for those properties? And what about income from renting properties in Thailand which don't have tax treaty with Portugal, will they tax you 28% on that?

2. If one have NHR, living in Portugal and wants to start providing consulting services online - should he/she opened Portugal company and will this income be taxed at 28%?

 

[JustAnotherNomad]

I know some users here that never filled anything. Anybody knows more?

https://www.sovereigngroup.com/news...nt-nhrs-now-face-large-tax-bills-in-portugal/

 

[disegrate]

In any case, it seems that you can fly under the radar for though years until the NHR runs out. I am not surprised as most NHR guys are actually perpetual travellers not residing in Portugal. And only make 50k per year.

Yes, but what structures do they have? SMLLC or MMLLC? Because in the second one there seems to have been a ruling that manages to make the Portuguese tax authorities “accept” the situation. But for the first one it's not clear, do you know anything more?

 

[Marzio]

the second one there seems to have been a ruling that manages to make the Portuguese tax authorities “accept” the situation.

Did you read the ruling?

The second partner was tax resident in US and paying taxes.

the first one it's not clear

It's very clear, you are generating a PE in Portugal by managing US LLC from there.

The question you have to ask is: "Am I ok running the risk of potentially getting caught?"

 

[disegrate]

The question you have to ask is: "Am I ok running the risk of potentially getting caught?"

Clear. What % do you think is the risk, indicatively? (Are you an international tax lawyer? Or a similar expert?) Do you know people who have been doing this for years? But then, if they ever find someone in such a situation, what do they risk?

Did you read the ruling?

Sure. I read that. In fact I said AT accepts it because it is a multi member LLC (with US resident).