Portuguese NHR + Estonian e-residence company taxes

Can anybody confirm which taxes you pay if you’re a sole owner of Estonian company and permanently live in Portugal with NHR granted.
So in that case you pay salary (Category A income) to yourself part of which considered for company management (thus taxed in Estonia) and another part as professional service (not taxed in Estonia as you are not resident there) would it be exempt from PT taxes under NHR? In a whole (both parts)?
Or “effective management rules” will ban this?

HI there,

Have you managed to obtain some more info?


HI @MadNoMad. The salary part (cat. A income) should be exempt as long as it is subject to tax in Estonia. The professional services part should not be tax exempt since (I guess) you (i.e. yourself, as service provider) don’t have a permanent establishment in Estonia and you don’t spend more than 183 days there.
Have you considered paying dividends to yourself instead of paying yourself professional services income?
Take care and stay safe

Hello @guifig, paying dividends involves 21% charge…
So paying a salary looks more tax effective.

Where did you get those 21% from @MadNoMad?