Law library · double tax treaties

Portugal’s tax treaties in English, with the Portuguese text

The double tax conventions our clients rely on most, article by article, with the protocols that amended them and the effect of the Multilateral Instrument (MLI). Where English is an authentic language of the treaty, we publish the official English text; otherwise our translation.

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Withholding tax rates under each treaty

Maximum tax the source State may charge when the beneficial owner is resident in the other State. Each treaty page sets out every condition, with links to the article.

TreatyDividendsInterestRoyaltiesMLI
United Statessigned 19945% · 15%5%: company holding at least 25% for 2 years10%0%: governments; bank loans of 5+ years10%Not covered: the US is not party to the MLI
United Kingdomsigned 20250% · 10% · 15%0%: company holding at least 10% for 1 year; 15%: property investment vehicles0% · 5% · 10%5%: banks; 0%: the State and central bank5%Not applicable: the 2025 treaty has its own principal purpose test
Germanysigned 198015%no reduced rate for holdings10% · 15%10%: bank loans; 0%: central banks10%Not yet in effect: Germany’s listing of Portugal is pending
Francesigned 197115%no reduced rate for holdings10% · 12%10%: certain French bonds5%Applies since 2021
Spainsigned 199310% · 15%10%: company holding at least 25% for 365 days15%5%Applies since 2023
Netherlandssigned 19990% · 10%0%: EU Parent-Subsidiary Directive0% · 10%0%: the State and public bodies; EU Directive for associated companies10%EU Directive for associated companiesApplies since 2021
Switzerlandsigned 19740% · 5% · 15%0%: company holding at least 25% for 2 years; 5%: 25% holding or pension fund0% · 10%0%: associated companies (25%, 2 years), the State0% · 5%0%: associated companiesCovered, not yet in effect (Swiss notification pending)
Brazilsigned 200010% · 15%10%: company holding at least 25% for 2 years15%includes interest on equity (JCP); 0%: governments15%includes technical servicesNot in effect: Brazil has not ratified the MLI
United Arab Emiratessigned 20115% · 15%5%: company holding at least 10%, no minimum period0% · 10%0%: the State and government bodies5%Applies since 2021

Without a treaty, Portugal taxes dividends, interest and royalties paid to non-resident companies at 25% (Article 87(4) CIRC). Domestic law can be better than the treaty: dividends paid to a company in the EU, the EEA or a treaty State holding at least 10% for a year can be exempt (Article 14(3) CIRC). Treaty relief at source needs the certified form described in Article 98 CIRC.

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Treaties in the library

Signed 1994 · English: authentic textPortugal–United StatesConvenção Portugal–Estados Unidos

Dividends 5%/15%, interest 10%, royalties 10%.

31 articles with the protocolOpen the treaty →
Signed 2025 · English: authentic textPortugal–United KingdomConvenção Portugal–Reino Unido

Dividends 0%/10%/15%, interest 0%/5%/10%, royalties 5%.

30 articles with the protocolOpen the treaty →
Signed 1980 · English: authentic textPortugal–GermanyConvenção Portugal–Alemanha

Dividends 15%, interest 10%/15%, royalties 10%.

31 articles with the protocolOpen the treaty →
Signed 1971 · English: our translationPortugal–FranceConvenção Portugal–França

Dividends 15%, interest 10%/12%, royalties 5%.

35 articles with the protocolOpen the treaty →
Signed 1993 · English: our translationPortugal–SpainConvenção Portugal–Espanha

Dividends 10%/15%, interest 15%, royalties 5%.

29 articles with the protocolOpen the treaty →
Signed 1999 · English: authentic textPortugal–NetherlandsConvenção Portugal–Países Baixos

Dividends 0%/10%, interest 0%/10%, royalties 10%.

34 articles with the protocolOpen the treaty →
Signed 1974 · English: our translationPortugal–SwitzerlandConvenção Portugal–Suíça

Dividends 0%/5%/15%, interest 0%/10%, royalties 0%/5%.

30 articles with the protocolOpen the treaty →
Signed 2000 · English: our translationPortugal–BrazilConvenção Portugal–Brasil

Dividends 10%/15%, interest 15%, royalties 15%.

29 articles with the protocolOpen the treaty →
Signed 2011 · English: authentic textPortugal–United Arab EmiratesConvenção Portugal–Emirados Árabes Unidos

Dividends 5%/15%, interest 0%/10%, royalties 5%.

31 articles with the protocolOpen the treaty →
Applying the law

Cross-border income, taxed once and at the right rate

Dividends to a foreign parent, interest on a shareholder loan, royalties, a salary split between two countries: tell us the flow and we will tell you which treaty article applies, the rate and the forms.

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