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Portugal tax resident under NHR + US LLC

Speedrunner

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Mar 25, 2024
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Hey there,

SWIM is a Portuguese tax resident under the NHR scheme and lives in Portugal for at least 6 months a year. SWIM is doing independent advisory work for companies outside of Portugal to the tune of 6 figures USD per year.

How viable is it for SWIM to set up an entity such as Delaware (Or Wyoming) to issue the invoices for services rendered, and then later cash out to Portugal through dividends paying 0% due to NHR tax benefits? I know PE-related questions can be problematic but are they really? Is it ever enforced? What are the major risks?

Thank you.
 

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