Fiscal and Tax Law - Portugal

Belzuz Abogados has a solid experience in providing legal services and international tax advisory and has a multidisciplinary team working in close collaboration with the Madrid office, ensuring an integrated approach towards projects of its clients.

The Department of Tax Law gathers a team of attorneys specializing in the area of taxation which, according to the needs of its customers, structures optimization plans for growth, providing the business structures of a proper fiscal management.

 The following services are available within this area of practice:

Transfer pricing

Companies that carry out commercial or financial operations with related entities (related party transactions) must be able to prove to the Portuguese Tax Authorities that the terms and conditions established in these bundled transactions, in each tax period, comply with the arm’s length principle.

In addition, there is also the obligation to prepare and have a file with documentation on transfer prices for entities that record net sales and other income of 3,000,000 euros or more with reference to the previous year.

Thus, these entities that are required to maintain an organized transfer pricing file, which they must present to the Portuguese Tax Authorities when requested, shall have this file available before July 15 of the year following the operations (for entities whose tax year corresponds with the calendar year).

According to the experience of Belzuz Law Firm, this issue has been controlled by the Portuguese Tax Authority which - very often - requests companies to justify their pricing policy in intra-group transactions.

Belzuz Law Firm has a team of specialists who advise companies on transfer pricing matters, reviewing transactions, and confirming the obligation to organise the file.

Regarding taxable persons that are obliged to comply with transfer pricing file, Belzuz's team of tax experts shall support the companies in selecting and justifying the most appropriate transfer pricing method or methods for related party transactions, carrying out the research and documentation of prices, transactions or comparable entities.


More information about the Fiscal and Tax Law Department | (Portugal)

Corporate Income Tax
  • Consulting services including drafting opinions on tax structures and applications for binding information of the Portuguese tax authorities;
  • Monitoring of tax inspection proceedings initiated by the Portuguese Tax Authorities (PTA);
  • Assistance following tax procedures and penalties processes appealing before the administrative and tax courts;


More information about the Fiscal and Tax Law Department | (Portugal)

Value Added Tax
  • Support intending to optimize cash flow situation by means of VAT refunds or by recovering VAT from bad debts;
  • Optimize methods to deduct VAT incurred on taxpayers with deductions restrictions;
  • Assistance with electronic invoicing and guidance on business accounting system data requirements for tax audit purposes [SAF-T (PT)];
  • Advising the companies in complying with the accessory obligations such as the monthly communication of the invoices as well as the certification of invoicing programs;


More information about the Fiscal and Tax Law Department | (Portugal)

Personal Income Tax

We assist our clients, who are individuals’ persons, in complying with their declarative obligations that arise from obtaining incomes in Portuguese territory, resolving tax residence disputes, and double taxation issues.

More specifically, we are specialized in the Non-Habitual Residents regime and we successfully assist our clients in resolving over taxation issues in cases where there are taxable capital gains in Portugal from non-residents.

Additionally, it should be noted that we provide several consultancy services in this area, focused on strategic advice and tax optimization of the client's individual situation, with a special focus on clients with investments in cryptocurrencies.

We provide support to individual clients on the following subjects:

  • Individual and family tax planning, consultancy and strategic advice to resident and non-resident clients;
  • Support in obtaining the status of non-habitual residence regime and clarification of questions concerning taxation under this regime;
  • Verification of the conditions to be eligible for the tax regime of “ex-residents”;
  • Preparation of Personal Income Tax estimates;
  • Clarification of questions concerning the legal-tax framework applicable to the various types of income, e.g., employment income, professional income, investment income, real estate income, capital gains and net worth increases, as well as investments in crypto assets;
  • Tax planning of employment income and benefits;
  • Compliance with tax reporting obligations in Portugal, by residents and non-residents, namely, support in the preparation and submission of the Personal Income Tax returns, in Portugal – Modelo 3 IRS, and in the preparation and submission of the tax return Modelo 10;
  • Completion and submission of RFI Forms;
  • Resolution of tax residence conflicts;
  • Resolution of international double taxation issues;
  • Preparation of administrative claims, audition appeals and hierarchical appeals, in order to claim personal income tax assessments;
  • Preparation of arbitration and judicial proceedings regarding Personal Income Tax.


More information about the Fiscal and Tax Law Department | (Portugal)

  • Structuring economic holdings;
  • Foreign investment consultancy specially on tax obligations;
  • Support on mergers and acquisitions;
  • Alongside with the Madrid office, we provide an integrated service to Iberian companies and International groups.


More information about the Fiscal and Tax Law Department | (Portugal)

Social Security
  • Consulting and litigation services with reference to Social Security contributions;


More information about the Fiscal and Tax Law Department | (Portugal)

Special consumption taxes
  • Consultancy services and litigation support on special taxes matters including customs proceedings and communitary framework;


More information about the Fiscal and Tax Law Department | (Portugal)

Tax and Customs litigation and arbitration

The divergences between the Portuguese Tax and Customs Authority and the taxpayers, resulting in the issuance of additional tax assessments and tax alerts of different kind, are proliferating and becoming more common every day.

In fact, the Portuguese Tax and Customs Authority is increasingly cross-checking the worldwide tax information and the assets of each taxpayer that is deemed resident for tax purposes in Portugal, and for this reason several disputes arise.

The Tax Department of Belzuz Advogados in Portugal is very experienced in all matters of Portuguese taxation and assists their clients in all subjects related to tax litigation, whether administrative or judicial, in relation to all issues related to taxes, duties and contributions.

We provide a detailed study of each client's situation to offer the best advice and solution for each case, always acting in their best interest before the decisions of the tax authorities and the courts.

Our team is duly qualified to represent and advise its clients in all phases of:

  • Administrative complaints and hierarchical appeals (reclamação graciosa e recurso hierárquico)
  • Judicial claims
  • Tax enforcement proceedings
  • Tax inspections
  • Tax offence proceedings and respective appeals
  • Arbitration proceedings at the Centre for Administrative Arbitration
  • Judicial appeals against decisions of the tax courts and the Centre for Administrative Arbitration


More information about the Fiscal and Tax Law Department | (Portugal)

Taxation of non-residents and non-habitual residents (RNH)

Belzuz Advogados has extensive experience dealing with issues related to the non-habitual resident status, providing advice to both national and foreign individuals and companies. Due to its Iberian presence and having offices in Madrid, Oporto and Lisbon, Belzuz Advogados has been advising residents from Spain in the proceedings of changing their tax residence to Portugal and obtaining the non-habitual resident status.

Belzuz Advogados' Tax Department provides direct and personalized support to its clients from the moment before the change of residence and accompanies the entire procedure to obtain the non-habitual resident status and the recognition of a high value-added activity in Portugal. Legal and tax support is also provided in all situations related to non-habitual resident status that may arise during the period of application of this tax regime.

Belzuz Advogados' Tax Department provides, inter alia, the following services:

Prior to the change of residence:

  • Preparing opinions with consideration of the possibility of granting non-habitual resident status;
  • Studying the impact in the case of the changing of residence and of the non-habitual resident status;
  • Specific analysis, aimed at each client, of the taxation rules on their income under the non-habitual residents’ tax regime, analyzing the international Conventions to avoid double taxation and exit tax issues;
  • Supervising the visa and residence permit procedures in Portugal for third-country nationals;
  • Reviewing and preparing the documents required to obtain the Portuguese Tax number as non-resident;
  • Legal certification of documents;
  • Nominating tax representatives of residents of third-country nationals;
  • Obtaining before the Portuguese tax authorities the Portuguese tax number as non-resident.

Change of residence and non-habitual resident status proceedings:

  • Reviewing and preparing the documents required for the change of residence;
  • Legal certification of documents;
  • Registering the change of residence to Portugal before the Portuguese tax authorities;
  • Presenting the non-habitual resident application to the Portuguese tax authorities;
  • To frame the professional activity within the scope of the list of high value-added activities.

After obtaining the non-habitual resident status:

  • Support in filing the income tax returns (Form 3 IRS) to be submitted as non-habitual residents in Portugal;
  • Obtaining residence and / or tax residence certificates;
  • Completing and instructing the forms applying International Conventions in order to avoid double taxation on income;
  • Completing and instructing the forms to obtain tax refund in case of international double taxation on income;
  • Informing the Portuguese tax authorities of any change in the tax register;
  • Supporting and supervising the proceeding of cancelation of the register before the Portuguese tax authorities when leaving the country;
  • Support in filing the income tax returns (Form 3 IRS) to be submitted as non-residents in Portugal.


More information about the Fiscal and Tax Law Department | (Portugal)

Investment in Portugal
  • Planning and implementation of corporate structures of representations of non-resident companies in Portugal (branches, subsidiaries or corporations);
  • Tax Consultancy on joint ventures, corporate reestructurings, contracts, mergers and acquisitions and other operations;


More information about the Fiscal and Tax Law Department | (Portugal)



Belzuz Abogados - Madrid office

Nuñez de Balboa 115 bis 1

  28006 Madrid

+34 91 562 50 76

+34 91 562 45 40

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Belzuz Abogados - Lisbon office

Av. Duque d´Ávila, 141 – 1º Dtº

  1050-081 Lisbon

+351 21 324 05 30

+351 21 347 84 52

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Belzuz Abogados - Oporto office

Rua Julio Dinis 204, Off 314

  4050-318 Oporto

+351 22 938 94 52

+351 22 938 94 54

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