About Taxbordr: founder-led PT vs ES analysis
Taxbordr is a Portugal tax advisory firm founded by Telmo Ramos, Ordem dos Economistas Cédula nº 16379, formerly KPMG Luxembourg and EY Lisbon. We model PT versus ES decisions for international families, founders, and investors weighing Lisbon, Porto, the Algarve, Madrid, Barcelona, or Valencia. The deliverable is a written Position Memo signed by Telmo, with side-by-side regime, wealth, inheritance, capital gains, and exit-cost lines. The Spain-side numerical positions are coordinated with a Spanish counsel where the case warrants.
Headline regimes: IFICI vs Beckham, side by side
IFICI under Portugal's EBF art 58-A taxes qualifying Cat A and Cat B Portuguese-source income at 20 percent flat for ten consecutive years. Foreign-source Cat A, B, E, F, and G income is exempt under CIRS art 81 n.º 4. Pensions and blacklisted-jurisdiction income are not exempt. Beckham, the Spanish inbound regime under Article 93 LIRPF and Royal Decree 687/2005, taxes Spanish-source employment income at 24 percent up to €600,000 and 47 percent above. Beckham covers the year of arrival plus the five subsequent years (six total), and 2022's Startup Law extended it to remote workers and certain professionals. Beckham excludes income from a permanent establishment in Spain unless caught by separate rules. Foreign-source employment income for Beckham residents is generally not Spanish-taxable, but coverage is narrower than IFICI's exemption method, and Beckham does not cover Cat B self-employment in the same way IFICI does.
Wealth tax: zero in Portugal, real in Spain
Spain levies the Impuesto sobre el Patrimonio at the regional level, with state-level wealth-tax structures and the federal solidarity layer (Impuesto Temporal de Solidaridad de las Grandes Fortunas) applying at progressive bands of 1.7 percent / 2.1 percent / 3.5 percent on net wealth above €5.35 million / €10.7 million per the 2023-2024 framework. Madrid offered a 100 percent regional bonification, leading the federal layer to step in. Portugal has no wealth tax. The closest analogue is AIMI under CIMI arts 135-A to 135-M, an annual surcharge on Portuguese real-estate VPT above €600,000 at 0.7 percent, 1 percent, or 1.5 percent. AIMI applies only to Portuguese-property VPT, not to securities, deposits, or non-Portuguese real estate. For a €5 million net-worth household, the wealth-tax differential alone compounds materially over a ten-year IFICI window.
Inheritance tax: 0 percent for Portuguese family, regional in Spain
Portugal does not have a stand-alone inheritance tax. Gratuitous transfers run through Imposto do Selo. CIS art 6 alínea e) exempts transfers to spouse, descendants, and ascendants. Other beneficiaries pay 10 percent under Verba 1.2 of the TGIS, with an additional 0.8 percent layer on Portuguese real estate. Spain levies Impuesto sobre Sucesiones y Donaciones at regional rates ranging from 7.65 percent to 34 percent before regional bonifications, which differ markedly between Madrid (high bonification) and other comunidades. For long-term planning by HNW families, the Portuguese family-exemption is a structural advantage that often outweighs the regime differential.
Capital gains: securities and real estate
Portugal taxes residents on securities capital gains at 28 percent flat under CIRS art 72 (with optional aggregation under englobamento). Post-2024, the inclusion rate for long-held securities follows graduated relief: 10 percent for holdings of 2-5 years, 20 percent for 5-8 years, 30 percent for 8 years or more, applied to listed securities under specific conditions. Real estate gains are taxed on 50 percent of the gain at progressive CIRS rates per CIRS art 43.2, with the primary-residence reinvestment exemption under CIRS art 10.5 conditional on reinvestment in habitual residence in Portugal, the EU, or the EEA. Spain taxes capital gains at progressive rates of 19 percent up to €6,000, 21 percent to €50,000, 23 percent to €200,000, 27 percent to €300,000, and 28 percent above €300,000 (2024 framework), applied to both securities and real estate. Beckham residents are taxed only on Spanish-source gains; non-Spanish-source gains generally fall outside Beckham scope.
Real estate transactions: IMT vs ITP
Portugal applies IMT at acquisition under CIMT, with tiered rates set in Lei 73-A/2025 and a primary-residence relief under CIMT art 6. IMI, the annual property tax under CIMI art 112, runs at 0.3 percent to 0.45 percent for urban property and up to 0.8 percent for rural property, calculated on VPT (Valor Patrimonial Tributário, typically 50-70 percent of market value), not market value itself. Spain applies ITP (Impuesto sobre Transmisiones Patrimoniales) at 6-10 percent depending on region, plus IBI annually. Both countries apply transfer taxes at acquisition; Spain's annual IBI is on market-value-based reference numbers in many municipalities, structurally different from VPT-based IMI.
Corporate tax for owner-managers
Portugal applies IRC at 17 percent under CIRC art 87, lowered by Lei 64/2025 of 7 November 2025 from the previous 19-21 percent range, with a 15 percent SME rate on the first €50,000 of taxable profit per CIRC art 87(2). Derrama estadual under CIRC art 87-A and tributações autónomas under CIRC art 88 add layers for higher-margin operators. Spain applies Impuesto sobre Sociedades at 25 percent general, 23 percent for small companies, and a startup rate of 15 percent for the first profitable year and three subsequent years for qualifying startups. Owner-manager comp packages need to model both IRPF and Sociedades against IFICI plus IRC, accounting for Sociedades dividend-distribution mechanics and Portuguese tributação autónoma on certain dividend flows.
The framework for choosing
PT versus ES is rarely a one-line answer. The deciding factors are: regime fit (does your activity qualify for IFICI or Beckham?), wealth profile (over €5 million net worth tilts to PT for the wealth-tax differential), family-transfer planning (PT family exemption tilts decisively to PT), capital-gains profile (securities-heavy holders need to model the post-2024 graduated relief), and lifestyle. We model the comparison with your numbers and produce a Position Memo with a recommended sequence.
What this guide is not
This page is general guidance, not advice on your specific situation. The Spain-side positions are simplified for a comparative reading and would be confirmed by a Spanish counsel before any decision is acted on.
Frequently Asked Questions
What is the headline difference between IFICI and Beckham?
IFICI is 20 percent for 10 years on qualifying Portuguese-source Cat A and Cat B income, with a foreign-source exemption under CIRS art 81 n.º 4. Beckham is 24 percent for 6 tax years on Spanish-source employment up to €600,000 and 47 percent above, under Article 93 LIRPF, with foreign-source income generally outside its scope.
Does Portugal have wealth tax?
No personal wealth tax. AIMI applies only to Portuguese real-estate VPT above €600,000 at progressive 0.7-1.5 percent under CIMI arts 135-A to 135-M. Spain has Impuesto sobre el Patrimonio at the regional level plus the federal Solidaridad surcharge at 1.7-3.5 percent on net wealth above €5.35 million.
Is Portugal better for inheritance planning than Spain?
Usually yes for direct-family transfers. CIS art 6 alínea e) exempts spouse, descendants, and ascendants. Spain's Impuesto sobre Sucesiones y Donaciones runs 7.65-34 percent at the regional level before bonifications, which differ widely by region. For multi-million-euro family wealth, the Portuguese family-exemption is often the deciding line.
Can I use IFICI and Beckham together?
No. They are mutually exclusive residency regimes in different countries. You can only be a tax resident of one at a time under CIRS art 16 and the Spanish residency tests. A residency change mid-decade can extend the combined relief window, but the planning is technical.
How does Portugal tax securities held long-term?
CIRS art 72 sets a 28 percent flat rate. Post-2024 graduated relief reduces the inclusion rate to 10 percent for 2-5 year holdings, 20 percent for 5-8 years, and 30 percent for 8 years or more on qualifying listed securities. Real estate residents face 50 percent inclusion at progressive rates per CIRS art 43.2.
Which country has lower corporate tax?
Portugal at 17 percent (Lei 64/2025) versus Spain at 25 percent general / 23 percent small. Portuguese SMEs pay 15 percent on the first €50,000. Spanish startups can apply 15 percent for four years. Owner-manager comp design needs to model dividend-distribution and IFICI-IRC interactions.