Golden Visa (investment fund pathway): do non-residents need to file yearly Portuguese tax returns?

Residencies & citizenships Portugal Golden Visa
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Hi everyone,

I’m hoping to get some advice from others who have gone through the Portugal Golden Visa process.

I applied for the Golden Visa last year and made my investment through the IMGA Ações Portugal fund. I’m not planning to sell the investment until I complete the Golden Visa requirements. I also don’t expect to spend more than about a month per year in Portugal, so I should remain a non-resident for tax purposes.

As part of my legal package with my lawyer, I paid for “5 years of tax representation.” My understanding was that this would cover handling tax-related matters connected to my NIF during the Golden Visa period. They recently messaged me and recommended me to file an annual tax return in Portugal to reflect zero income. However, they told me that filing a Portuguese income tax return is not included in that service because tax returns are handled by accountants.

They are recommending that I file a nil Portuguese tax return each year, even though I currently have no Portuguese income and do not expect to sell the investment during the Golden Visa period.

I have a few questions for people who have been in a similar situation:

  1. If you are a Golden Visa holder who is not tax resident in Portugal, do you still file an annual Portuguese tax return?
  2. Is it common for lawyers or advisors to recommend filing a yearly nil return in this situation?
  3. Is it normal that “tax representation” does not include tax return filing?
  4. For those invested in Portuguese funds like IMGA Ações Portugal, did you need to report anything annually if you didn’t sell or receive distributions?

I’m trying to understand whether filing a yearly nil return is actually necessary from a compliance perspective, or if it’s something many Golden Visa investors choose not to do unless they have Portuguese income.

Any experiences or advice would be greatly appreciated.

Thanks!

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Hi there, same investment here (since 2021). I have never filed a tax return. Advised if there was no income, no need to file one. “Tax representation” is a person, located in Portugal, who will forward any inquiries from the tax authorities to you and was formerly a requirement. They are not expected to prepare any tax returns on your behalf, if needed. It could literally be a friend who lives in Portugal.

The tax rep service should be pretty inexpensive (was about 100 euro a year when I first signed up with a service). Since signing up for a tax rep, I have heard from them a total of zero times (except when the annual renewal comes up)

Sounds like a way to earn fees for something that isn’t necessary… but interested in other perspectives.

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Sounds like we have the same law firm. I asked our VC fund manager their thoughts, and they asked their lawyer his thoughts. He agreed with the above statement that you do not need to file a nil return. I may have to file once my fund starts distributing dividends but I’ll figure that out when/if it happens.