I am currently a nomad with a structure (self-employed) based in France. It was convenient at the beginning, but with the high taxes and the fact that I do not actually stay there much, I am looking for other options.
My situation is such that I do not stay more than 183 days in any country, and my main client is based in Asia. My occupation aligns very well with NHR2.0 requirments (R&D, tech, etc.)
It seems that Portugal can be a good solution, and in addition, I have access to a house there.
I have several questions but the two mains one currently are :
Is it possible to be a tax resident of Portugal while staying less than 183, by having my main residency here and just traveling around the rest of the time ?
Will the flat rate + the social security be applied only at prorata on the time I actually spent in Portugual to work ?
Is it feasible to be self-employed and benefit the NHR2.0, and if so, what kind of structure should be set up?
If anyone has some inputs, they would be very welcome! Thanks!
The short answer is yes. Just make register and don’t deregister, and make sure you don’t trigger tax residency elsewhere.
No, I believe you’d need to prove that the income you generate abroad are taxed abroad in that case.
You cannot qualify for IFICI by being self-employed. The most similar option is to set up a company and become e.g. the director of it. The company will be taxed in Portugal, but you could pay out most of the income in the same year to reduce its profits to close to 0. What you pay out as a salary would of course be taxed at 20% + SS, unless you opt to stay on the progressive rates (which could make sense if the company doesn’t generate that much income).
The company is needed to qualify for IFICI in the first place—unless you have some other role that would qualify you (e.g. being on the board of a startup, etc).
Of course, once you qualify for IFICI you get the exemptions/reductions on any income other type of income that you may have (foreign capital income, gains, self-employment, etc)—not just the income you get through the company. And there’s no minimum turnover required in the company either, but 50% of its revenue needs to come from export of goods or—in your case—services.
You may want to check out these two webinar recaps from Fresh Portugal as well:
Regarding work done outside of Portugal, I remember reading that if the work is not done in Portugal, it is not taxed, but it is unclear in the case of being paid by the company.
Nonetheless, if I follow your idea of paying most of my current income as salary, through a company, I believe I would have to pay employer + employee social contribution? That would mean, just for social contribution, around 35%.
I am still confused on how the NHR can be profitable in that type of case, I am probably lacking knowledge in tax montage in Portugal.