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.
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.
| Treaty | Dividends | Interest | Royalties | MLI |
|---|---|---|---|---|
| United Statessigned 1994 | 5% · 15%5%: company holding at least 25% for 2 years | 10%0%: governments; bank loans of 5+ years | 10% | Not covered: the US is not party to the MLI |
| United Kingdomsigned 2025 | 0% · 10% · 15%0%: company holding at least 10% for 1 year; 15%: property investment vehicles | 0% · 5% · 10%5%: banks; 0%: the State and central bank | 5% | Not applicable: the 2025 treaty has its own principal purpose test |
| Germanysigned 1980 | 15%no reduced rate for holdings | 10% · 15%10%: bank loans; 0%: central banks | 10% | Not yet in effect: Germany’s listing of Portugal is pending |
| Francesigned 1971 | 15%no reduced rate for holdings | 10% · 12%10%: certain French bonds | 5% | Applies since 2021 |
| Spainsigned 1993 | 10% · 15%10%: company holding at least 25% for 365 days | 15% | 5% | Applies since 2023 |
| Netherlandssigned 1999 | 0% · 10%0%: EU Parent-Subsidiary Directive | 0% · 10%0%: the State and public bodies; EU Directive for associated companies | 10%EU Directive for associated companies | Applies since 2021 |
| Switzerlandsigned 1974 | 0% · 5% · 15%0%: company holding at least 25% for 2 years; 5%: 25% holding or pension fund | 0% · 10%0%: associated companies (25%, 2 years), the State | 0% · 5%0%: associated companies | Covered, not yet in effect (Swiss notification pending) |
| Brazilsigned 2000 | 10% · 15%10%: company holding at least 25% for 2 years | 15%includes interest on equity (JCP); 0%: governments | 15%includes technical services | Not in effect: Brazil has not ratified the MLI |
| United Arab Emiratessigned 2011 | 5% · 15%5%: company holding at least 10%, no minimum period | 0% · 10%0%: the State and government bodies | 5% | 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.
Treaties in the library
Dividends 5%/15%, interest 10%, royalties 10%.
31 articles with the protocolOpen the treaty →Signed 2025 · English: authentic textPortugal–United KingdomConvenção Portugal–Reino UnidoDividends 0%/10%/15%, interest 0%/5%/10%, royalties 5%.
30 articles with the protocolOpen the treaty →Signed 1980 · English: authentic textPortugal–GermanyConvenção Portugal–AlemanhaDividends 15%, interest 10%/15%, royalties 10%.
31 articles with the protocolOpen the treaty →Signed 1971 · English: our translationPortugal–FranceConvenção Portugal–FrançaDividends 15%, interest 10%/12%, royalties 5%.
35 articles with the protocolOpen the treaty →Signed 1993 · English: our translationPortugal–SpainConvenção Portugal–EspanhaDividends 10%/15%, interest 15%, royalties 5%.
29 articles with the protocolOpen the treaty →Signed 1999 · English: authentic textPortugal–NetherlandsConvenção Portugal–Países BaixosDividends 0%/10%, interest 0%/10%, royalties 10%.
34 articles with the protocolOpen the treaty →Signed 1974 · English: our translationPortugal–SwitzerlandConvenção Portugal–SuíçaDividends 0%/5%/15%, interest 0%/10%, royalties 0%/5%.
30 articles with the protocolOpen the treaty →Signed 2000 · English: our translationPortugal–BrazilConvenção Portugal–BrasilDividends 10%/15%, interest 15%, royalties 15%.
29 articles with the protocolOpen the treaty →Signed 2011 · English: authentic textPortugal–United Arab EmiratesConvenção Portugal–Emirados Árabes UnidosDividends 5%/15%, interest 0%/10%, royalties 5%.
31 articles with the protocolOpen the treaty →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.