rpba - the non habitual tax resident regime - updated 07.03.2017

THE PORTUGUESE NON-HABITUAL TAX RESIDENT (NHR) REGIME

Ricardo da Palma Borgesricardorpbapt

wwwrpbapt

Basic Features of the IRS Regime

Worldwide basis system for Personal Income Tax

(ldquoImposto sobre o Rendimento das Pessoas

Singularesrdquo hereinafter ldquoIRSrdquo) and credit

method to avoid international double taxation

Progressive IRS rates (higher bracket of 48 for

taxable income above euro 80640 additional

solidarity rate of 25 on taxable income above

euro 80000 and of 5 above euro 250000)

28 autonomous tax rate on rental income

capital income and capital gains on

shareholdings securities derivatives

autonomous warrants and certificates

2

There is still an extraordinary progressive surtax in

2017 (higher bracket of 321 for taxable income

above euro 80640) higher marginal rate of 48 + 5

+ 321 = 5621 in 2017

Portuguese tax residence for IRS purposes may be

acquired namely

a) Staying for more than 183 days in the Portuguese

territory whether these days are consecutive or

not in any 12-month period beginning or ending

in the given tax year

b) If staying for a shorter period having in the

Portuguese territory on any day during the period

referred above a dwelling under circumstances

that lead to the presumption of an intention to

hold and occupy it as a place of habitual abode

Why Portugal

29th country on the OECD Better Life Index

2016 (1) 5th on 2015rsquos Internations Quality of

Life Index (2)

According to The Huffington Post Algarve was

considered the Worlds best place to live or

retire in 2016 (3) and as reported by The

Telegraph Portugal is the 2nd best place to

retire abroad (4)

Portugal (httpenwikipediaorgwikiPortugal) has a number of attractive characteristics

01Quality of Life

3

(1) - httpwwwoecdbetterlifeindexorgcountriesportugal(2) - httpsinassets1-internationsgmbhnetdna-sslcomstaticbundlesinternationsexpatinsiderimages2015topicquality_of_life_index_fulljpg(3) - httpwwwhuffingtonpostcomkathleen-peddicordbest-places-to-retire-overseas_b_8917292html(4) - httpwwwtelegraphcoukfinancepersonalfinancepensions9677415The-10-best-places-to-retire-abroadhtml

Basic Features of the NHR Regime

Decree-Law nr 2492009 of September 23

created a new IRS regime for NHR individuals

This status is granted to individuals who become

residents for tax purposes in Portugal without

having been so in the previous five years

NHR individuals may enjoy such status for a ten-

year period after which they will be taxed under

the standard IRS regime

4

This new tax regime targets non-resident

individuals who are likely to establish a

permanent or temporary residence in Portugal

It establishes under certain conditions an IRS

exemption on foreign source income as well as

a limited taxation of income deriving from high

value added activities

NHR are issued Portuguese certificates of tax

residence The rationale of the regime is that we

are only switching over the credit method for

the elimination of international double taxation

for the exemption method


The particular features of the NHR regime may always

be amended by law for better or worse even for those

who have been granted NHR status prior to the

enactment of any change (although in such cases the

degree of change to the regime which is admissible

under Portuguese constitutional law is very debatable)

A change to the NHR regime could happen but it is not

likely as the regime was introduced in 2009 by a

government of the same center-left wing party

(ldquoPartido Socialistardquo) which is now in government with

the support of other (more) left-wing parties

Additionally there is currently no public debate or

controversy surrounding the NHR regime and no

changes to it have been included in the Government

Program approved by parliament (available at

httpwwwportugalgovptmedia18268168program

a-do-xxi-governopdf see pages 230 to 234 on tax

matters)5

The current Socialist party Government has just

declared the intention to revise the list of high value

added activities

In any case if such change happens i) even if NHR

status is abolished it cannot be taken away from

those that already have it at the time the change is

approved ii) Although the NHR status cannot be

taken away the regime could be made less attractive

(reducing the scope of the exemptions for instance)

even for those that have obtained it in the past To

what extent such change could be made is very

debatable under Portuguese administrative and

constitutional law Some changes would always be

admissible but in principle a change that would make

the NHR regime purely nominal (making NHR and

normal residents taxed in the same way or with only

very minor differences) should not be allowed

Assessing the degree of change that is allowed is very

difficult

6

02Weather

Weather and environment quality

(9th country on the OECD 2016

Better Life Index)

Why Portugal

03Sunshine

Estimated 3300 hours of sunshine

per year one of the highest rates

in Europe

Key Advantages

Foreign-sourced passive income (interest dividends certain royalties other

income from capital capital gains and income from immovable property)

derived by NHR is IRS exempt in Portugal (without progression except in the

case of capital gains on real estate) provided that it is potentially liable to

taxation in the source State under the rules of a tax treaty or of the OECD

Model Tax Convention (no effective taxation is required)

Foreign-sourced income from pensions is IRS exempt (with progression)

7

8

Modern and cosmopolitan country

Lisbon was elected 2nd best place to travel in 2015 (5)

and Porto was the best European destination for

2017 (6)

Lisbon was also ranked the 16th most livable city in

the world in Monocle Quality of Life Survey 2016

Best Cities to Live (7)

(5) - httpwwweuropeanbestdestinationscomtopeurope-best-destinations-2015(6) - httpwwweuropeanbestdestinationscombest-of-europeeuropean-best-destinations-2017(7) - httpsmonoclecommagazineissues95top-25-liveable-cities(8) - httpenwikipediaorgwikiList_of_World_Heritage_Sites_in_Portugal

05Cultural Offering

Portugal has a great list of ldquowondersrdquo declared a World Heritage Site by Unesco (8)

Fado (the Portuguese most traditional music genre) was considered by UNESCO Intangible Cultural

Heritage of Humanity in 2011

Why Portugal 04Modernity

Foreign-sourced employment income is IRS exempt (with progression)

provided that it is effectively taxed in the source State under the rules of a

tax treaty or of the OECD Model Tax Convention in the absence of the

former

Foreign-sourced employment income is IRS exempt (without progression) in

Portugal provided that it is effectively taxed in the source State under the

rules of a tax treaty or of the OECD Model Tax Convention in the absence of

the former and that it is income derived from high value added activities of

a scientific artistic or technical nature

9

Key Advantages

Foreign-sourced income from independent personal services is IRS exempt

(without progression) in Portugal provided that it is potentially liable to taxation in

the source State under the rules of a tax treaty or of the OECD Model Tax

Convention in the absence of the former (no effective taxation is required) and that

it is income derived from high value added activities of a scientific artistic or

technical nature as defined by Ministerial Order

Income deriving from employment or independent personal services of a domestic

or foreign source but not qualifying for the mentioned exemptions will be liable to

autonomous taxation at a special 20 flat rate and not to the general and

progressive IRS rates (currently of up to 5621 for yearly taxable income above

euro250000) provided that it derives from high value added activities of a scientific

artistic or technical nature10

Key Advantages

PORTUGUESE ENGLISH

1 - Arquitectos engenheiros e teacutecnicos similares

101 ndash Arquitectos

102 ndash Engenheiros

103 ndash Geoacutelogos

1 - Architects engineers and similar technicians

101 ndash Architects

102 ndash Engineers

103 ndash Geologists

2 - Artistas plaacutesticos actores e muacutesicos

201 ndash Artistas de teatro bailado cinema raacutedio e televisatildeo

202 ndash Cantores

203 ndash Escultores

204 ndash Muacutesicos

205 ndash Pintores

2 - Visual artists actors and musicians

201 ndash Theater ballet film radio and television Artists

202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores

302 ndash Consultores fiscais

3 - Auditors

301 ndash Auditors

302 ndash Tax Consultants

High Value Added Activities of a Scientific Artistic or Technical Nature

11

PORTUGUESE ENGLISH

4 - Meacutedicos e dentistas

401 ndash Dentistas

402 ndash Meacutedicos analistas

403 ndash Meacutedicos cirurgiotildees

404 ndash Meacutedicos de bordo em navios

405 ndash Meacutedicos de cliacutenica geral

406 ndash Meacutedicos dentistas

407 ndash Meacutedicos estomatologistas

408 ndash Meacutedicos fisiatras

409 ndash Meacutedicos gastroenterologistas

410 ndash Meacutedicos oftalmologistas

411 ndash Meacutedicos ortopedistas

412 ndash Meacutedicos otorrinolaringologistas

413 ndash Meacutedicos pediatras

414 ndash Meacutedicos radiologistas

415 ndash Meacutedicos de outras especialidades

4 - Doctors and dentists

401 ndash Dentists

402 ndash Analyst Doctors

403 ndash Surgeons

404 ndash Board doctors in ships

405 ndash General Practitioners

406 ndash Dentists

407 ndash Dentist Doctors

408 ndash Physiatrists

409 ndash Gastroenterologists

410 ndash Ophthalmologists

411 ndash Orthopaedists

412 ndash Otorhinolaryngologists

413 ndash Paediatricians

414 ndash Radiologists

415 ndash Doctors in other specialties


12

PORTUGUESE ENGLISH

5 - Professores

501 ndash Professores universitaacuterios

5 - Teachers

501 ndash University professors

6 - Psicoacutelogos

601 ndash Psicoacutelogos

6 - Psychologists

601 ndash Psychologists

7 - Profissotildees liberais teacutecnicos e assimilados

701 ndash Arqueoacutelogos

702 ndash Bioacutelogos e especialistas em ciecircncias da vida

703 ndash Programadores informaacuteticos

704 ndash Consultoria e programaccedilatildeo informaacutetica e actividades

relacionadas com as tecnologias da informaccedilatildeo e informaacutetica

705 ndash Actividades de programaccedilatildeo informaacutetica

706 ndash Actividades de consultoria em informaacutetica

707 ndash Gestatildeo e exploraccedilatildeo de equipamento informaacutetico

708 ndash Actividades dos serviccedilos de informaccedilatildeo

709 ndash Actividades de processamento de dados domiciliaccedilatildeo de

informaccedilatildeo e actividades relacionadasportais Web

7 - Professional services technicians and similar

701 ndash Archaeologists

702 ndash Biologists and experts in life sciences

703 ndash Computer Programmers

704 ndash Consulting and computer programming and activities related to

information and computer technology

705 ndash Computer programming activities

706 ndash Computer consultancy activities

707 ndash Management and operation of computer equipment

708 ndash Activities of information services

709 ndash Activities of data processing hosting information and related

activitiesWeb portals


13

PORTUGUESE ENGLISH


informaccedilatildeo e actividades relacionadas

711 ndash Outras actividades dos serviccedilos de informaccedilatildeo

712 ndash Actividades de agecircncias de notiacutecias


714 ndash Actividades de investigaccedilatildeo cientiacutefica e de desenvolvimento

715 ndash Investigaccedilatildeo e desenvolvimento das ciecircncias fiacutesicas e naturais

716 ndash Investigaccedilatildeo e desenvolvimento em biotecnologia

717 ndash Designers


activities

711 ndash Other information service activities

712 ndash Activities of news agencies


714 ndash Scientific research and development

715 ndash Research and development of science physical and natural

716 ndash Research and development in biotechnology

717 ndash Designers

8 - Investidores administradores e gestores

801 ndash Investidores administradores e gestores de empresas promotoras

de investimento produtivo desde que afectos a projectos elegiacuteveis e com

contratos de concessatildeo de benefiacutecios fiscais celebrados ao abrigo do

Coacutedigo Fiscal do Investimento aprovado pelo Decreto -Lei nordm 2492009

de 23 de Setembro

802 ndash Quadros superiores de empresas

8 - Investors administrators and managers

801 ndash Investors administrators and managers of companies

promoting productive investment if allocated to eligible projects

under tax benefits contracts awarded under the Tax Code for

Investment approved by Decree-Law No 2492009 of 23

September

802 ndash Senior employees of companies


14

15

06Gastronomy

The Portuguese gastronomy is as rich and

diverse as its heritage and landscapes and has

recently been internationally recognized with

14 Michelin star restaurants in 2016 (9)

Portugal is also one of the best wine tourism

destinations Our country had 578 prizes at

the 2016rsquos Decanter World Wines Awards

(DWWA) (10) and also achieved 16 Grand Gold

114 Gold and 227 Silver Medals in the 2016rsquos

Concours Mondial de Bruxelles (11)

(9) - httpportugalconfidentialcom2016-michelin-star-restaurants-in-portugal(10) - httpawardsdecantercomDWWA2016

(11) - httpresultsconcoursmondialcomindexphppage=resultsampformular[ConcoursID]=59

Why Portugal

Law nr 159-D2015 of December 30 had terminated the existing extraordinary surtax as of

January 1 2017

However the State Budget Law for 2017 has extended the application of the extraordinary

surtax for the higher brackets of income with some rate adjustments and a phased withholding

tax repeal during 2017

Consequently the extraordinary surtax still applies to income derived in 2017 the higher

bracket being 321 for taxable income above euro 80640

This surtax is applicable to the non-exempt employment or independent personal services

income deriving from high value added activities of a scientific artistic or technical nature

obtained by NHR liable to autonomous taxation at a special 20 flat rate as well as to any non-

exempt income liable to the general and progressive IRS rates

16

Key Disadvantages

17

08Other Languages Spoken

A large part of the population speaks foreign languages

especially English Spanish and French

Portugal was ranked 13th out of 70th countries in the EF

Global English Proficiency Index 2015 (13)

07EducationThere is a significant number of International Schools

throughout Portugal attended by both Portuguese and

foreign students

Portugal is ranked as the 8th best in the World according

to the U21 Rankings of National Higher Education

Systems 2016 (12)

Why Portugal

(12) - httpuniversitas21comnewsdetails220u21-ranking-of-national-higher-education-systems-2016(13) - httpwwwefeduptepi

Other Attractive Features of the Portuguese IRS Taxation of Individuals

However several other attractive features exist in the Portuguese taxation system of

individuals

Firstly several capital gains are excluded from IRS taxation such as those on

a) shares and quotas acquired before 1 January 1989

b) real estate except land for construction owned before 1 January 1989

c) a taxpayers personal and permanent residence insofar as the sale proceeds are

reinvested in another personal residence in the Portuguese European Union or

European Economic Space territory

Contributions made by the employer to pension funds and life and health insurance

schemes are not regarded as IRS taxable employment income provided that certain

conditions are met18

19

09Daily FlightsAbout 300 daily flights from Portugal

to foreign countries

Porto Airport ranks among the best

airports in Europe since 2006 (14)

10Convenient Location

for Globetrotters

Portugal ranked 1st on Globe Spots

Top 10 countries in 2013 (15)

(14) - httpwwwaciaeroAirport-Service-QualityASQ-AwardsCurrent-WinnersBest-Airport-By-RegionEurope(15) - httpwwwglobespotscombesttravelphpyear=2013

Why Portugal

Widening of the exemptions for foreign-sourced income to encompass

― all passive income (interest dividends certain royalties other income from capital capital

gains on any foreign asset including shares and income from immovable property)

regardless of the liability to potential taxation at source under an existing tax treaty or the

OECD Model Tax Convention

mdash independent personal services income of any kind provided that it is potentially liable to

taxation in the source State under the rules of a tax treaty or of the OECD Model Tax

Convention

Inclusion of actuaries airline pilots and directors and managers of all companies regardless of

their activity sector and of the existence of a tax benefit contract with the Portuguese State in the

list of high value added activities of a scientific artistic or technical nature which qualify non-

exempt employment and independent personal services income for the special 20 flat rate

20

2015 Proposals by the IRS Reform Commission (the 1st

rejected by the previous Government the 2nd may yet be considered by the current Government)

21

11Sports

Top conditions for sports (sailing diving biking trekking

horse riding golf - with some of the best World courses (16))

(16) - httpworldgolfawardscomawardworld-best-golf-destination2015

Why Portugal

Procedure to Register as Tax Resident in Portugal

Registering as a tax resident in Portugal is a requirement to obtain the NHR status which means

that those wishing to apply for the regime must

i register as non-resident taxpayers (optional in some cases)

ii obtain residence permits (for non-EU nationals) or long-term residence certificates (for EU

nationals)

iii register as tax residents

iv request the password to access the tax authoritiesrsquo website and

v only then apply for the NHR status

Applications must be submitted until March 31 of the tax year following that in which Portuguese

tax residence is acquired From August 2 2016 onwards the applications have to be submitted on

the tax authoritiesrsquo website

Moreover individuals must submit a statement whereby they solemnly declare that they have not

fulfilled the criteria necessary for being considered a Portuguese tax resident during the preceding

five years22

23

Value for money in real estate investments (which

have undergone significant decreases since 2008)

12Investments

In comparison with other major European

countries Portugal is highly affordable (17)

13Cost of Living

(17) - httpwwwnumbeocomcost-of-livingcountry_resultjspcountry=Portugal

Why Portugal

24

An official guide on the NHR Regime

from the Portuguese tax authorities is

available in English here

httpinfoportaldasfinancasgovptNRr

donlyresD0C80C76-3DA8-4B90-A1E4-

FF53BD34EF950IRS_RNH_ENpdf

An official guide on the request of the

password to access the tax authoritiesrsquo

website is also available in English here


donlyres278F9580-C488-4AC4-AD0F-

B1508A52F0880senhasenglishpdf

Standard legal and tax step plan on becoming a Portuguese non-habitual tax resident

1 Advice on double residence and taxation of income and wealth

2 Obtain a Portuguese non-resident taxpayer number (appointing a tax representative if necessary) ndash Optional in some cases

3 Legal assistance in the purchase or lease of real estate

4

Obtain a residence permit (for non-EU nationals) from the Foreigners and Borders Service or a long-term residence certificate (for EU nationals) from the local city council

5 Register as resident taxpayer

6 Request the password to access the tax authoritiesrsquo website

7 Submit an application to the NHR regime

8 Obtain Portuguese tax resident certificates and file a non-resident tax application in the country of origin

9 Activate the Electronic Post Box

10 File annual tax returns

25

Portugal has a high quality

health system offering

both public and

private healthcare

14Health System

For instance according to the

2016 OECD Health Statistics

the average life

expectancy in Portugal in 2014

was 812 years (18)

(18) - httpstatsoecdorgindexaspxDataSetCode=HEALTH_STAT

Why Portugal

Taxation of capital income summary OECD Model

Characterization

NHR

ndash foreign source income

taxation in PTShares distribution of profits to

the shareholdersDividends Exempt

Shares alienation Capital gains Not exempt (28 rate)

Bonds Interest Exempt

Bank deposits Interest Exempt

Investment Funds redemption

and alienation Capital gains Not exempt (28 rate)

Investment Funds distribution

of profitsDividends Exempt

Insurance without guaranteed

capitalOther Income Not exempt (28 rate)

Insurance with guaranteed

capitalInterest Exempt

26

Assuming that (i) Investment Funds are considered persons for corporate income orcapital tax purposes and residents of a Contracting State (ii) income derived from thedistribution of profits by Investment Funds is subject to the same tax treatment asincome from shares (iii) redemption of Investment Fundsrsquo participation units or shares isnot treated by the Source State as a distribution of profits

In short plain-vanilla dividends and interest are exempt from IRS under the NHR regimecapital gains on shares and investment funds are not

Taxation of capital income the issue of capital gains

Law nr 152010 of June 26 has abolished a long standing IRS exclusion for capital gains

on shares held for more than 12 months This has relevant consequences for the NHR

regime as its tax exemption for capital gains was built with that exclusion in mind and in

such a way that it is only applicable to capital gains that may be taxed in the source State

under the rules of a tax treaty entered into by Portugal (or if no treaty exists according to

the rules of the OECD Model Tax Convention)

This implies that most capital gains (maxime on foreign shareholdings and other

securities) will remain taxable in Portugal as normally both Portuguese tax treaties and

the OECD Model Tax Convention establish in this case that the residence State has

exclusive competence to tax Deviations from the OECD Model namely those enabling

the source State taxation of Capital Gains on securities or Other Income will interestingly

enable NHR exemptions to encompass those items of income

27

Taxation of capital income some pitfalls

28

Tax transparent entities ndash those not considered standard taxpayers for corporate income tax purposestheir income flowing directly to their owners shareholders The qualification characterization of theseentities and their income in a cross-border context may raise complex issues for the NHR regime and evenhinder the possibility to obtain exemptions

Tax haven entities ndash those blacklisted as such by a Portuguese Ministerial Order Definitely to avoid notonly their income will not be exempt under the NHR regime but it will also be taxed at a 35 autonomousrate Furthermore a shareholder of a tax haven entity risks the application of Portuguese ControlledForeign CompaniesrsquoEntitiesrsquo (CFC) rules [you will find the said Portuguese Ministerial Order and ourinfographic on these rules here [httpwwwslidesharenetRPBArpba-infographic-international-tax-transparency-controlled-foreign-entities] Finally losses on the sale of shares securities autonomouswarrants and certificates are not deductible when the counterparty in the sale operation is located in atax haven

Derivatives ndash their presence in investment portfolios may generate income characterized as capital gainswhich as already explained is not normally NHR exempt In practice it is possible to offset income andlosses in derivatives issued in the same foreign country but it is not feasible to offset such differences onthose with different originating countries This implies a taxation of the aggregate positive income foreach issuing country (line-by-line inclusion) and a denial of deductibility of the aggregate negative loss foreach issuing country (line-by-line disallowance) One cannot achieve a taxation or deductibility of theoverall positive net income loss of all derivatives of the various countries

Foreign exchange ndash Pure foreign exchange gains ie those deriving from spot currency transactions arenot liable to IRS in Portugal However foreign exchange gains or losses embedded in assets or rights maybe taxable due to the need to report income in Euro for IRS purposes

Taxation of capital income conclusion

29

So-called ldquoDividendsrdquo and ldquoInterestrdquo arising from foreign companies that are not in themselves taxed (eitherbecause they are not liable to Corporate Income Tax or because they are in tax havens) may also not be exemptunder the NHR regime

The wealth management area is complex as (i) there are lots of types of financial instruments (ii) when dealingwith foreign products one has to make an effort to understand them and to qualify their income for purposes ofthe NHR regime (iii) Portugal has different baskets for capital income and capital gains and many limitations onthe offsetting of losses (iv) this tax compliance even if there is an income exemption of the product under theNHR regime is in itself an extra burden represented by the tax consultantsrsquo time fees

Despite the NHR regime being frequently marketed as a ldquoworld of easerdquo it is very important to (i) properly plandirect financial investments (NHR educating the asset manager) or (ii) depending on the type of investmentsthe size of the financial portfolios and also on the number of annual operations of purchase and sale to bemade it may be worthwhile to consider setting up wealth management products structures namely throughthe use of wrappers envelopes (such as unit-linked life insurance portfolio management companies certificates) that hold the financial portfolio enabling a more pure ldquomathematicalrdquo or ldquoaccountingrdquo profit to beachieved creating a veil between the investor (and hisher IRS statement) and hisher investments avoiding theprevious slide complexities and allowing for the investments not to be tax reported to be tax deferred untilthere is a withdrawal of funds from the insurance policy itself or a dividend distribution from the company In anunit-linked insurance policy when the withdrawal occurs there may exist some small taxation under the NHRregime but there will just be one line of income to report in the IRS statement (annual insurance policy fees willnevertheless apply) In a company the dividend should be NHR exempt (but of course management andaccounting fees will apply) Regarding the certificates the income derived from them as long as the certificatesin question assure the holder a minimum value above the subscription amount should be NHR exempt If that isnot the case the income so derived will be taxable at a 28 autonomous rate

30

15Economic Progress

Successful conclusion of the Troikarsquos (International Monetary

Fund European Central Bank and European Union) financial

assistance program (2011-2014) on May 17 2014

16Political Stability

Portugal is a developed

democracy with political and

social stability

Why Portugal

Pension Income vs Capital Income

31

Pensions are odd animals

There are many types of pensions and not all things that one may believe as suchwill be so eg special retirement products or retirement bank accounts mayqualify as capital income and not as true pensions

Income qualified as a pension by the source State may not meet therequirements of the tax treaties or even the Portuguese IRS Code definitions ofpension As the NHR is a Portuguese unilateral regime for relief frominternational double taxation the income qualification for this purpose may haveto be made in accordance with Portuguese domestic law and not in accordancewith tax treaties or the source Statersquos view

For instance income of investment products provided by an insurance companywhere (i) the funding contributions were exclusively made by the beneficiarywith no link to a previous employment orand (ii) the capital is not guaranteedorand (iii) there is the possibility of redemption may not be exempt under theNHR regime depending on the tax treaty in force

Direct or indirect purchasing of real estate

Property Transfer Tax of up to 6 (at higher rates but with a cap of 6 if not for permanent

housing as in an acquisition by a company) and Stamp Tax of 08 on the price or taxable value

(whichever higher)

Property Ownership Tax of 08 for rural real estate and between 03-05 for urban real estate

(exemption for permanent housing if the taxable value does not exceed euro 125000 for households

with a IRS taxable income not higher than euro 153300 on purchase for resale by companies

entrepreneurs during 3 years)

Stamp Tax on 5 or more year term financing of 06 but exemption applies to interest paid on

permanent housing loans

The State Budget Law for 2017 enacted in substitution of the 1 ldquoLuxuryrdquo Stamp Tax on housing

real estate with a taxable value above 1 million an Additional to the Property Ownership Tax

(ldquoAPOTrdquo)

32


This new APOT applies to owners usufructuaries or superficiaries of urban property for housing

purposes or building land located in Portugal on January 1st of the relevant year

Single owners with residential real estate or land for construction in Portugal above euro 600000 of

taxable value (Valor Patrimonial Tributaacuterio or VPT) are liable to APOT at a 07 rate on the

surplus of the euro 600000 If the sum of the taxable values exceeds euro 1000000 the surplus is

subject to a marginal rate of 1

Owners which are married or in a civil partnership and choose the joint taxation regime ndash for

purposes of the APOT ndash are only liable to APOT if the sum of the taxable value of their real estate

is above euro 1200000 The APOT applies a 07 rate on the surplus of the euro 1200000 If the sum

of the taxable values exceeds euro 2000000 the surplus is subject to a marginal rate of 1

If the taxpayers obtain income attributable to immovable property subject to the APOT the latter

may be deducted from the IRS due in respect of rental income (Schedule F) or business income

obtained from rental or hosting activities (Schedule B) 33


If a company holds real estate the APOT rate will be applied on the full taxable value of the real

estate at a rate of 04 ndash not only on the surplus of a threshold

If the owner is a company and the real estate is simply used by its shareholderdirector or any

member of the corporate bodies of such company (including their respective spouses

ascendants or descendants) the tax rate will be of 07 on its full taxable value If the sum of

their taxable values exceeds euro 1000000 the surplus is subject to a marginal rate of 1 In our

opinion if the real estate is leased by the company to the shareholder or director the tax rate will

be of 04

Taxpayers may choose for Corporate Income Tax purposes (i) to deduct APOT as an expense or

(ii) to deduct the APOT from the tax due limited to the fraction corresponding to the income

generated by that real estate in the context of rental or hosting activities and up to that tax due

34


Numerous punitive measures on acquisition and holding of Portuguese real estate by a

blacklisted tax haven company ndash namely APOT rate of 75 on the sum of the taxable values of

the real estate without possibility of deducting the charge for Corporate Income Tax purposes

Sale of shares in a foreign (tax resident) company holding Portuguese real estate does not trigger

Property Transfer Tax Stamp Tax IRS Corporate Income Tax

Sale of shares in a Portuguese (incorporated) company holding Portuguese real estate does not

trigger Property Transfer Tax Stamp Tax except if it is a Sociedade por Quotas (private limited

company) and one of the quotaholders obtains 75 of the capital or the number of holders is

reduced to 2 quotaholders married or living in a civil partnership So 74 26 Lda ownership

structures are common

Portuguese tax treaties with the Netherlands Belgium and Luxembourg envisage exclusive taxing

rights for the residence State on the sale of land rich companies

35

Inheritance and gift

Inheritance and gifts are subject to Stamp Tax in Portugal However inheritance and gifts between

close family (spouses living partners children grandchildren parents and grandparents) are

exempt assets outside Portugal are not even taxable and when tax is due on the Portuguese

assets (between siblings cousins uncle and nephew etc) it is so at a low rate ndash 10 when an

inheritance 10 plus 08 when a gift of real estate is concerned

As of November 2015 the Socialist party with the parliamentary support of three far-left parties

(the Left Block the Communist and the Green parties) has formed a new government The

Socialist party has proposed in its electoral program the reintroduction of inheritance taxation

between spouses and direct line descendants for ldquohigh valuerdquo estates (in principle those with a

taxable value above 1 million Euros with a rate of 28 applying to the surplus) but ldquotaking into

account the need to avoid phenomena of multiple inheritance taxationrdquo It is therefore likely that a

mild form of inheritance taxation may be re-introduced in Portugal but it is not clear how it will

target NHR with non-Portuguese assets due to the caveat in commas

36


Accordingly changes to inheritance taxation (which is currently very generous as inheritance

between direct family is exempt assets outside Portugal are not taxable and when tax is due on

Portuguese assets it is so at a low rate - 10) seem much more likely than a change of the NHR

regime as the Government Program intends to tax the cases that are now exempt (most notably

in inheritances between direct family) However the relevant aspects remain fully uncertain (for

instance if foreign assets will or not be taxed if donations will or not be taxed in the same way as

inheritances how should the euro 1000000 be valued etc) Developments on this issue therefore

have to be monitored

37

Received by Inheritance Gift

Movable property

Located in Portugalclose family 0 0

other people 10 10

Not located in Portugalclose family 0 0

other people 0 0

Real estate


other people 10 108


other people 0 0

Movable property subject to registration license or

inscription

Registered in Portugalclose family 0 0

other people 10 10

Not registered in Portugalclose family 0 0

other people 0 0

Credit rights or rights with an economic content (over

individuals or legal entities)

When the debtor has its residence head office effective management or a permanent establishment in Portugal and in any

case provided that the beneficiary is a Portuguese resident

close family 0 0

other people 10 10

When the debtor does not have its residence head office effective management or a permanent establishment in Portugal

Or if the beneficiary is not a Portuguese resident

close family 0 0

other people 0 0

38

Inheritance and gift Stamp Tax as it applies today


Shareholdings

In a corporation whose head office or effective management is located in Portugal or which has a permanent establishment in Portugal and in any case the beneficiary being a Portuguese

resident

close family 0 0

other people 10 10

In a corporation which does not have its head office its effective management in Portugal or a permanent establishment in Portugal


close family 0 0

other people 0 0

Monetary values deposited in bank accounts

In an institution whose head office effective management is in Portugal or which has a permanent establishment in Portugal

close family 0 0

other people 10 10

In an institution whose head office and effective management is not in Portugal and which has not a permanent establishment in

Portugal

close family 0 0

other people 0 0

IndustrialIntellectual property rights (and related rights)

Registered or subject to registration in Portugalclose family 0 0

other people 10 10

Not registered nor subject to registration in Portugalclose family 0 0

other people 0 0

39


Other inheritance and gift aspects

Inheritance or gift will give rise to a new date of acquisition and an assessment of tax value

relevant for Stamp Tax and for future IRS capital gains (date of acquisition and original acquisition

value by deceased are lost)

In brief regarding inheritance or gift of real estate located in Portugal

Directly held real estate

i) Close family is exempt from Stamp Tax

ii) Other situations involving the gratuitous disposal of Portuguese assets are taxed through Stamp Tax

Real estate held through companies The inheritance or gift of

i) A foreign (incorporated) company even towards Portuguese residents is not liable to this tax (assuming

its effective management is not in Portugal and that the real estate is not a permanent establishment of

the company otherwise above exemption 10 rate applies)

ii) A Portuguese (tax resident) company towards non-Portuguese residents is not liable to this tax

iii) A Portuguese (tax resident) company towards Portuguese residents above exemption 10 rate

applies

40

41

17Peaceful Country

According to the 2016primes

Global Peace Index Portugal

ranks 5th out of 163

countries (19)

(19) - httpstaticvisionofhumanityorgsitesdefaultfilesGPI20201620Report_2pdf

Why Portugal

Compliance Submission of yearly tax returns

42

When tax residence in Portugal is acquired no entry wealth statement has to be made

Furthermore in Portugal there is no wealth tax nor any annual wealth statement

However IRS forces taxpayers to disclose foreign bank accounts (at least those directly held) in

the annual tax return There is no need to declare the amounts held in such accounts therein

Only the BIC and IBAN of such accounts should be declared The Portuguese bank accounts do

not have to be reported in the annual tax return in the same way as the foreign accounts

Therefore a yearly tax return must be submitted until May 31 of each year starting from the

year following the one in which Portuguese tax residence is acquired

In this tax return all worldwide income obtained in Portugal or abroad has to be declared

(even if exempt under the NHR regime) For income obtained outside Portugal not exempt

under NHR regime tax levied abroad will be considered creditable (with some limitations)

against the IRS

43

18Portuguese Passport

Citizenship

If the head of the household qualifies for residency

in Portugal all the dependents will automatically

qualify so with no any additional costs

Moreover Portugal has one of the worlds most

valuable passports (20) and the Portuguese

Citizenship was ranked as the 16th most valuable in

the World by Quality of Nationality Index (QNI) (21)

(20) - httpswwwpassportindexorgbyRankphp(21) - httpsnationalityindexcom

Why Portugal

The Portuguese NHR Regime

For more information on our Residence Planning Services please visit our

microsite wwwnonhabitualtaxresidentcom or scan the below QR code with your

smartphone

Should you require further information on this issue please check our Information

Note on this subject available at httpwwwslidesharenetRPBAthe-non-habitual-tax-

resident-regime-rpba30102014

44


Proper legal advice is recommended before any decision is taken

to become a Portuguese tax resident and more so if one wishes

to take full advantage from the NHR status RPBA has an in-

depth knowledge and expertise on this regime

To book a consultation or to obtain our professional fees on this

subject please e-mail us (Ricardo da Palma Borges and Marta

Carmo) ricardorpbapt martarpbapt

45

Recent Tax Recognition

Chambers amp Partners ndash Ricardo Band 2 RPBA Band 3 (2016) and Ricardo Band 1 RPBA Band 3 (2015 2014 2013)

Legal 500 ndash Ricardo and Bruno are Recommended Lawyers RPBA Band 3 (2016 2015 2014 2013)

World Tax ndash Ricardo mentioned RPBA Tier 3 (2017 2016 2015 2014)

Best Lawyers ndash Ricardo recognised as Tax Law Lawyer of the Yearrdquo (2017) and ranked under the Tax Law practice area and the Tax

Planning subspecialty (2016 2015 2014 2013 2012 2011)

Corporate LiveWire - Ricardo da Palma Borges chosen as the winner of the Finance Award for Tax Lawyer of the Year ndash Portugal

(2017) Ricardo da Palma Borges chosen as the winner of the Finance Award for Excellence in Tax Planning ndash Portugal (2016)

World Transfer Pricing ndash Ricardo mentioned RPBA Tier 3 (2016)

Whoacutes Who Legal ndash Ricardo ranked as a top lawyer in the Corporate Tax Lawyers directory (2016 2013)

Expert Guides ndash Ricardo da Palma Borges recognised in the ldquoTaxrdquo edition of the Expert Guides which annually identifies the best tax

lawyers in each country (2016)

Global Law Experts - RPBA Tax Law Firm of the Year in Portugal (2016)

Tax Directors Handbook ndash Ricardo mentioned RPBA Tier 3 (2015)

Corporate Intl - RPBA Boutique Tax Law Firm of the Year in Portugal (2016)

Corporate Intl Magazine Legal Award ndash RPBA Boutique Tax Law Firm of the Year in Portugal (2014)

Acquisition International Tax Award ndash RPBA Portuguese Tax Law Boutique Firm of the Year (2015)

Acquisition International Legal Award ndash RPBA Boutique Law Firm of the Year ndash Portugal (2014)46

47

General warning disclaimer copyright and authorised use

In the preparation of this presentation every effort has been made to offer current correct and clearlyexpressed information However the said information is intended to afford general guidelines only Thispresentation reflects information current at 7 March 2017

This presentation is distributed with the understanding that RICARDO da PALMA BORGES amp ASSOCIADOSSOCIEDADE DE ADVOGADOS SP RL is not responsible for the result of any actions taken on the basis ofinformation herein included nor for any errors or omissions contained herein

RICARDO da PALMA BORGES amp ASSOCIADOS SOCIEDADE DE ADVOGADOS SP RL is not attemptingthrough this work to render legal or tax advice and the information in this presentation should be used as aresearch tool only and not in lieu of individual professional study with respect to client legal matters

Portuguese domestic legislation foreign legislation EU Directives and tax treaties have anti-abuseprovisions and each actual client structure should be analysed taking those into account

RICARDO da PALMA BORGES amp ASSOCIADOS SOCIEDADE DE ADVOGADOS SP RL is the copyright ownerof this presentation and hereby grants you a non-exclusive non-transferable license to use this presentationsolely for your internal business provided that you do not modify its content in any way and that you do notretain any copyright or other proprietary notices displayed on such content You may not otherwisereproduce modify distribute transmit post or disclose the content on this presentation without RICARDOda PALMA BORGES amp ASSOCIADOS SOCIEDADE DE ADVOGADOS SP RLrsquos prior written consent

(+351) 212 402 743

geralrpbapt

wwwrpbapt

wwwlinkedincomcompanyrpba

wwwslidesharenetrpba

15

Basic Features of the IRS Regime

Worldwide basis system for Personal Income Tax

(ldquoImposto sobre o Rendimento das Pessoas

Singularesrdquo hereinafter ldquoIRSrdquo) and credit

method to avoid international double taxation

Progressive IRS rates (higher bracket of 48 for

taxable income above euro 80640 additional

solidarity rate of 25 on taxable income above

euro 80000 and of 5 above euro 250000)

28 autonomous tax rate on rental income

capital income and capital gains on

shareholdings securities derivatives

autonomous warrants and certificates

2

There is still an extraordinary progressive surtax in

2017 (higher bracket of 321 for taxable income

above euro 80640) higher marginal rate of 48 + 5

+ 321 = 5621 in 2017

Portuguese tax residence for IRS purposes may be

acquired namely

a) Staying for more than 183 days in the Portuguese

territory whether these days are consecutive or

not in any 12-month period beginning or ending

in the given tax year

b) If staying for a shorter period having in the

Portuguese territory on any day during the period

referred above a dwelling under circumstances

that lead to the presumption of an intention to

hold and occupy it as a place of habitual abode

Why Portugal



Life Index (2)





retire abroad (4)


01Quality of Life

3











4































matters)5



added activities
















difficult

6

02Weather



Better Life Index)

Why Portugal

03Sunshine



in Europe

Key Advantages








7

8




2017 (6)





05Cultural Offering








former






9

Key Advantages













Key Advantages

PORTUGUESE ENGLISH







102 ndash Engineers




202 ndash Cantores



205 ndash Pintores



202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores


3 - Auditors

301 ndash Auditors



11

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

Why Portugal



Life Index (2)





retire abroad (4)


01Quality of Life

3











4































matters)5



added activities
















difficult

6

02Weather



Better Life Index)

Why Portugal

03Sunshine



in Europe

Key Advantages








7

8




2017 (6)





05Cultural Offering








former






9

Key Advantages













Key Advantages

PORTUGUESE ENGLISH







102 ndash Engineers




202 ndash Cantores



205 ndash Pintores



202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores


3 - Auditors

301 ndash Auditors



11

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15










4































matters)5



added activities
















difficult

6

02Weather



Better Life Index)

Why Portugal

03Sunshine



in Europe

Key Advantages








7

8




2017 (6)





05Cultural Offering








former






9

Key Advantages













Key Advantages

PORTUGUESE ENGLISH







102 ndash Engineers




202 ndash Cantores



205 ndash Pintores



202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores


3 - Auditors

301 ndash Auditors



11

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15



















matters)5



added activities
















difficult

6

02Weather



Better Life Index)

Why Portugal

03Sunshine



in Europe

Key Advantages








7

8




2017 (6)





05Cultural Offering








former






9

Key Advantages













Key Advantages

PORTUGUESE ENGLISH







102 ndash Engineers




202 ndash Cantores



205 ndash Pintores



202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores


3 - Auditors

301 ndash Auditors



11

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

6

02Weather



Better Life Index)

Why Portugal

03Sunshine



in Europe

Key Advantages








7

8




2017 (6)





05Cultural Offering








former






9

Key Advantages













Key Advantages

PORTUGUESE ENGLISH







102 ndash Engineers




202 ndash Cantores



205 ndash Pintores



202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores


3 - Auditors

301 ndash Auditors



11

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

Key Advantages








7

8




2017 (6)





05Cultural Offering








former






9

Key Advantages













Key Advantages

PORTUGUESE ENGLISH







102 ndash Engineers




202 ndash Cantores



205 ndash Pintores



202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores


3 - Auditors

301 ndash Auditors



11

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

8




2017 (6)





05Cultural Offering








former






9

Key Advantages













Key Advantages

PORTUGUESE ENGLISH







102 ndash Engineers




202 ndash Cantores



205 ndash Pintores



202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores


3 - Auditors

301 ndash Auditors



11

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15




former






9

Key Advantages













Key Advantages

PORTUGUESE ENGLISH







102 ndash Engineers




202 ndash Cantores



205 ndash Pintores



202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores


3 - Auditors

301 ndash Auditors



11

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15













Key Advantages

PORTUGUESE ENGLISH







102 ndash Engineers




202 ndash Cantores



205 ndash Pintores



202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores


3 - Auditors

301 ndash Auditors



11

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

PORTUGUESE ENGLISH







102 ndash Engineers




202 ndash Cantores



205 ndash Pintores



202 ndash Singers

203 ndash Sculptors

204 ndash Musicians

205 ndash Painters

3 - Auditores

301 ndash Auditores


3 - Auditors

301 ndash Auditors



11

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

PORTUGUESE ENGLISH


401 ndash Dentistas
















401 ndash Dentists


403 ndash Surgeons



406 ndash Dentists











12

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

PORTUGUESE ENGLISH

5 - Professores


5 - Teachers


6 - Psicoacutelogos


6 - Psychologists



























13

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

PORTUGUESE ENGLISH









717 ndash Designers


activities







717 ndash Designers






de 23 de Setembro







September



14

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

15

06Gastronomy













Why Portugal


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15


January 1 2017










16

Key Disadvantages

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

17








foreign students



Systems 2016 (12)

Why Portugal




individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15



individuals










19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

19






for Globetrotters




Why Portugal








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15








Convention





20



21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

21

11Sports




Why Portugal






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15






nationals)









five years22

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

23



12Investments



13Cost of Living


Why Portugal

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

24

















4








25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

25



both public and

private healthcare

14Health System



the average life


was 812 years (18)


Why Portugal


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15


Characterization

NHR















26
















27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15














27


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15


28






29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15


29




30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

30

15Economic Progress







social stability

Why Portugal


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15


31








(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15




(whichever higher)









(ldquoAPOTrdquo)

32























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15























be of 04




34














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15














35















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15















36










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15










37


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15


Movable property


other people 10 10


other people 0 0

Real estate


other people 10 108


other people 0 0


inscription


other people 10 10


other people 0 0





close family 0 0

other people 10 10



close family 0 0

other people 0 0

38



Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15


Shareholdings


resident

close family 0 0

other people 10 10



close family 0 0

other people 0 0



close family 0 0

other people 10 10


Portugal

close family 0 0

other people 0 0



other people 10 10


other people 0 0

39
















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15















applies

40

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

41

17Peaceful Country




countries (19)


Why Portugal


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15


42












against the IRS

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

43


Citizenship









Why Portugal




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15




smartphone




44









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15









45



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15



















47







(+351) 212 402 743

geralrpbapt

wwwrpbapt



15

(+351) 212 402 743

geralrpbapt

wwwrpbapt



15