Defensible exit planning for Australian high earners relocating to Portugal. No vague promises — just the numbers, the rules, and the evidence that holds up.
Every calculation below uses the same assumptions the ExitProof calculator applies when you select "Portugal" as your destination. These are not optimistic projections — they reflect current ATO rules (ITAA36 s6(1), TR 2023/1) and Portuguese tax law as of 2024-25.
* Includes one-time CGT exit event (~$40k). Portugal taxes residents on worldwide income. Progressive rates (14.5–48%) apply. NHR regime status for 2024-25 requires verification with a Portuguese tax advisor — changes from 2024 limit NHR availability for many Australian residents. Non-resident CGT on shares = 0% from departure date.
* Exit CGT on $800k portfolio: ~$75k. Portuguese tax on worldwide income — rental income and investment returns remitted to Portugal are taxable at progressive rates. NHR was historically useful for pension/rental income but has been restricted since 2024. DTA with Australia provides double-taxation relief.
* CGT exit event on $2M portfolio: ~$140k. At $2M+ income, Portugal's progressive rates + solidarity surtax create a meaningful tax burden. The 48% top rate applies above ~€81k (2024). NHR restrictions from 2024 significantly reduce the tax benefit for high earners compared to the pre-2024 NHR era. Work with a Portuguese tax specialist before relying on NHR projections.
You are a Portuguese tax resident if you spend 183 or more days in Portugal during a calendar year (January 1–December 31). Portuguese residents are taxed on worldwide income.
| Concept | Threshold | Relevance for Australian high earners |
|---|---|---|
| 183-day rule | 183+ days physically present in Portugal in a calendar year | Primary trigger for Portuguese tax residency |
| Permanent home | A habitual home in Portugal (ownership, tenancy, or right of use) | Alternative trigger even under 183 days — if you have a permanent home, residency may apply |
| Worldwide income | Employment, self-employment, pension, rental, dividends, capital gains | All income sourced worldwide is potentially taxable in Portugal |
| NHR regime | 10-year regime for new residents, subject to significant 2024 changes | Historically attractive for foreign pension/rental income; restricted since 2024 |
Portugal's Non-Habitual Resident (NHR) regime was significantly reformed from 1 January 2024. Key changes: NHR is no longer available to residents who were tax resident in the previous 5 years in another EU/EEA state (anti-abuse rule); many income categories (employment, pensions, rental, crypto) now excluded from NHR favourable treatment; standard progressive tax rates (up to 48%) now apply to most foreign income for NHR holders from 2024. Do not plan your move around NHR projections without verifying current eligibility with a Portuguese tax lawyer.
| Taxable income (€) | Rate | Notes |
|---|---|---|
| Up to €7,479 | 13.25% | |
| €7,479 – €11,284 | 17.00% | |
| €11,284 – €15,992 | 21.00% | |
| €15,992 – €20,700 | 26.50% | |
| €20,700 – €26,355 | 28.50% | |
| €26,355 – €38,632 | 35.00% | |
| €38,632 – €50,483 | 37.00% | |
| €50,483 – €78,834 | 43.50% | |
| Over €78,834 | 48.00% | Top marginal rate |
| High income (additional) | +2.5% | Solidarity surtax on income over €80k (separate scale) |
Reference: Portal das Finanças (Portuguese Tax Authority); Portuguese personal income tax rates 2024
Under s6(1) ITAA36, you are an Australian tax resident if you satisfy any one of four tests. You must fail all four to be a genuine non-resident. The ordinary concepts test is the battleground.
| Test | What it asks | Portugal-mover risk |
|---|---|---|
| 1. Ordinary concepts | Does your presence in Australia feel "usual and settled" — or temporary and casual? | HIGH — maintaining AU property + regular school-holiday returns sustains continuity of association |
| 2. Domicile | Is your domicile in Australia? (Presumed yes unless you establish a permanent place of abode overseas AND intend to stay) | MEDIUM — Portuguese tenancy + declared intent counters domicile presumption, but strong AU ties can sustain it |
| 3. 183-day test | Have you been physically present in Australia for 183+ days in the income year? | LOW — if you actually live in Portugal, you'll fail this |
| 4. Superannuation test | Does your employer pay compulsory superannuation contributions in Australia? | MEDIUM — remote work for AU employer may still generate AU super contributions |
The Australia-Portugal DTA was signed in 1983 and is older than many modern treaties. It includes the key provisions relevant to Australian expats, but with limitations compared to newer comprehensive treaties.
Each item directly addresses one of the six ordinary concepts factors (TR 2023/1 para 20). Portugal's DTA is supplementary — the evidence must establish genuine Portuguese residency first.
Headline numbers. Run the full comparison →
| Portugal | Dubai | Singapore | Stay in Sydney | |
|---|---|---|---|---|
| Personal income tax | 0–48% (progressive) | 0% | 0–22% | 37%–47% |
| AU CGT for non-residents | 0% on shares | 0% on shares | 0% on shares | N/A |
| DTA with Australia | Yes (1983 DTA) | None | Yes (comprehensive) | N/A |
| Evidence burden | Medium (DTA tie-breaker) | High (no treaty fallback) | Lower (comprehensive DTA) | N/A |
| Visa options | D7, D8, Golden (fund) | Golden Visa (10yr) | Employment Pass | N/A |
| EU access | Full EU + Schengen | No | No | N/A |
| 10yr leave-vs-stay delta (~$400k earner) | ~+$655k* | ~+$1.69M | ~+$1.65M* | Baseline |
* Portugal figures use standard progressive rates (48% top). NHR excluded from projections given 2024 reform uncertainty. Dubai and Singapore remain higher on pure tax savings. Portugal's value proposition includes EU access and quality of life — not tax alone.