Portugal NHR & Estonia e-Residency

[joffreylol]

Sorry for starting a new thread. I know that Portugal's NHR was discussed a lot and if I didn't have to please my girlfriend Portugal wouldn't be my first choice.

I'm a software engineer making websites and mobile apps working for a UK company remotely. I'm not physically tied to any country. I and my girlfriend want to move from a shitty Balkan country and Portugal might work for us.

I'm not sure how NHR could work for me because I have to actively do the work to get money. I don't passively earn stock dividends, pensions, etc. Martin linked this page from Belion Partners Portugal's Non-Habitual Resident (NHR) Tax Regime
It seems that I fall under ICT Technologists of eligible occupation. Foreign-source self-employment or sole trader income derived from an eligible occupation (see below). Can foreign-source self-employment work for me if I own Estonian OU? I can pay myself 100% salary without paying board member salary in Estonia Frequently asked questions | Xolo FAQ . I wonder if this money can be tax-free because of double tax treaties? There is an option of paying myself dividends at 20% or 25% if the salary wouldn't work, but I'm not sure if even that would work because of CFC.

Can anyone please give suggestions, what to do in my situation? Thank you.

 

[JosephLL]

It looks to me like you're conflating multiple things here. Not an expert, just follow sources about PT, it'd be great if someone more knowledgable could jump in.

NHR is a possibility that noone can actually guarantee you will get, for anyone who is a resident of PT but still not a citizen. Irrelevant of what kind of visa you have.

Main point is how you get into PT. The case of freelancers are not quite clear to me, and there are different opinions out there. You don't qualifiy for D7 route, because salary is not passive income. In order to qualify for D7 i think you'd have to pay yourself dividends (above mandatory threshold) which has a consequence of paying a 25% tax in Estonia.

There is D2 route for self-employed, but it's stricter than D7.

As far as salary income is in question, that tax has to payed where your residence is. So if you are not granted NHR status you have the same tax obligations on your salary like anyone else in PT.

It would be interesting to hear if anyone has experience here with D7 route as self-employed or remotely employed.

 

[joffreylol]

Oh snap, I was hoping for D7 visa. I read somewhere that PT will have some visa for remote workers in the future like what Estonia has recently introduced. Having 7200EUR in a bank account isn't a problem for me but proving passive income will be a problem. It seems that I have to go with dividend route and make it look like I'm receiving these dividends passively. I was hoping to avoid having to create substance somewhere and having to lie PT government. I guess my cheapest option is Bulgaria (10% cit + 5% dividend?) or Romanian microcompany with local employee (1% cit + 5% dividend?).