Returning ex-residents will benefit from a 50% exclusion on earnings from salaried employment (Category A) and business and professional income (Category B). Only half of the income will be taxed under the proposed changes in IRS rules. According to the State Budget Proposal for 2019, this regime will apply for five years from the year in which the citizen meets the eligibility conditions. Any entity responsible for withholding income earned by returning former residents will be subject to a withholding tax on half of the attributed income, thus ensuring full application of the tax break.
There are currently more than 420,000 registered foreigners residing in Portugal. Until 2000, the international population in Portugal never exceeded 2% of the total resident population. By 2017, the number of legalised foreign nationals represented almost 4%. Brazilians are the single largest group: 20%, followed by Cape Verdeans, Ukrainians, Romanians, Chinese and English.
Individuals who reside in tax havens and own residential property in Portugal are free from paying the 7.5% surcharge applied to the new Additional Municipal Property Tax (“AIMI”). Only companies domiciled in tax havens – offshore companies – are subject to the aggravated rate on the full ratable value (“VPT”) of residential properties. “AIMI” replaces Stamp Tax, which provided for the application of a tax rate of 1% on each property with a “VPT” greater than one million euros.