Benefitting from Portugal's NHR scheme as a freelancer with foreign clients

There’s been a lot of interesting content in this thread, however still not enough to completely clarify my position. In regards to Article 14 of the OECD model tax treaty:

(1) Income derived by a resident of a Contracting State in respect of professional services or other independent activities of a similar character shall be taxable only in that State unless he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. If he has such a fixed base, the income may be taxed in the other Contracting State but only so much of it is as attributable to that fixed base.

What if I say have an office or renting a co wroking space in the respective country? What if additionally a small percentage of my self employed income is actually taxed in that country because it is “attributable to that fixed base”, meaning I was working there for a few days a year?

In general, if you earned income (rental/dividend/salary/royalties) is from State A, you pay taxes in State A. If you earn it in State B, you pay taxes in State B. If you have income from various States, you pay taxes according to where you earn it, so you could be paying taxes in State A, B, C, etc. Depending if there is a double taxation agreement. Unless you are from the US.
If I am working remotely and renting a coworking space from Portugal but I get paid into an Irish bank account by my Irish employer, I pay taxes in Ireland. If I am remote working from Portugal but I have registered as a Portuguese freelancer, became resident, have the NHR approved, have a NIF and get paid into a Portuguese bank account by my Irish employer, I pay taxes in Portugal. If I rent out my house in Ireland, I pay taxes in Ireland for that rental income.
So with that logic, if you are UK registered company, get paid into your UK account from your UK clients (whether through salary or dividends), then you pay UK taxes even if you are based in a Portuguese location.
NHR is 20% tax (simplified tax) for 1st 10 years and social contributions 15% 2nd year onwards. The tax benefits of NHR is not useful for you unless you are a Portuguese legal entity paying Portuguese taxes. 20% of nothing is nothing.
If you don’t want to pay any taxes to any state, then you need to live a nomadic lifestyle. Get professional advise if that is what you wanted to do.


I’m a EU citizen who works as a freelancer for clients outside of Portugal. Due to the nature of my work, I do mainly long-term projects for a single client at a time. I read that working for a single client may pose a problem in Portugal, as one may be labeled as ‘dependent self-employed’. As a consequence, the client may be forced to pay part of your social security contributions:

The contracting entities are subject to a contribution rate of 10% when the economic dependence of the self-employee is higher than 80% and 7% if the economic dependence varies between 50% and 80%. The sole contribution rate of 5% ceases to exist. This measure produces effects as from 1 January 2018.

Source: Social Security – Self-employed individuals contributions regime | Tax flash | PwC Portugal

I understand that this rule was implemented to protect workers who are forced into self-employment. This does however not apply to me. Does anyone know if there are exemptions for foreign clients and/or higher incomes (80-100k€)? I can’t be the only person facing that problem, given that an economic dependence of 50% is easily reached if you work as a software developer on bigger projects for example.