Moving to Portugal Checklist 2026: Banks, Entities and Tax

A moving to Portugal checklist usually ends at the residence permit: a visa, a NIF, a lease, a bank account, done. For a family that owns a portfolio, a company or a trust, that is only the first move. The second runs through the banks, the entities and the advisors, and it has an order. Some decisions only work before your tax residence changes, that is, before Portugal starts taxing you as a resident; others only after. This guide sets out that order, from twelve months out to the first Portuguese IRS filing, and names who owns each step.

PWA does not manage money, hold mandates, take commissions or give regulated investment, tax or legal advice. The guide sequences who does what; the decisions stay with the licensed advisors.

What should a family organise before moving to Portugal?

Map every entity and account, tell each bank and update the CRS self-certifications, decide which advisor owns the tax-residence analysis in both countries, line up the documents for the NIF and the residence permit, and set one calendar for the first Portuguese tax year. Start about twelve months before the move, in that order.

Portugal fixes the start of your residence by fact, not by paperwork. Under article 16 of the IRS Code, you become resident if you spend more than 183 days in Portugal in any twelve-month period, or if you have a home there in conditions that suggest you intend to keep it as your habitual residence. Residence then runs from the first day of presence. Every decision about banks and entities is either before or after that day.

Moving to Portugal checklist: the timeline from twelve months out to the first IRS filing

Most lists of things to know before moving to Portugal are about schools, leases and climate. The table below is the other list: what a family with wealth has to sequence, who owns each task and which document proves it was done.

One person owns this calendar, and the family names that person before the first row starts. It can be a family member, the family office, the team that runs a family’s financial affairs, if there is one, or an outside coordinator; it cannot be six advisors who each own a row. The order matters because an entity decision taken after the residence date is a Portuguese resident’s decision, with Portuguese tax consequences. What that coordination looks like across countries is the subject of our cross-border wealth planning work.

IFICI, NHR and the Golden Visa in 2026: what is still open

Here is the Portugal NHR status, the IFICI regime that followed it and the Portugal Golden Visa in 2026, each as a dated fact. Whether any of them applies to you is decided by your tax advisor or your lawyer, not by a checklist and not by us.

NHR: closed to new entrants

Lei 82/2023 of 29 December, the 2024 State Budget, revoked the non-habitual resident regime from 1 January 2024. Its article 236 kept a transitional door open for people who became tax resident by 31 December 2024 and could show that the move was already under way in 2023, for example a residence visa or permit procedure started by 31 December 2023. For a family moving in 2026, the NHR is not available. Families already registered should confirm their remaining years with their tax advisor.

IFICI: for qualifying work, not for a portfolio

The regime that replaced it is IFICI, the tax incentive for scientific research and innovation in article 58.º-A of the Tax Benefits Statute, regulated by Portaria 352/2024/1 of 23 December 2024 and amended by Portaria 52-A/2025/1 of 25 February 2025, which moved all registrations onto the Portal das Finanças. According to the Tax Authority’s own FAQ, it applies a special 20% rate to employment and self-employment income from eligible activities for ten consecutive years. It is open to people who have not been Portuguese tax resident in the previous five years and who have never benefited from the NHR. Registration is due by 15 January of the year after you become resident; a late registration only takes effect from the year it is filed, which shortens the benefit. It is a regime for qualifying work. The eligibility call is your tax advisor’s.

Golden Visa (ARI): property routes closed

Lei 56/2023 of 6 October, in force from 7 October 2023, stopped new applications for residence permits for investment under the property routes. Applications already pending on that date stayed valid, and permits granted under the old rules can still be renewed. On renewal they convert into a permit for entrepreneurial immigrants, with a minimum stay of seven days in the first year and fourteen days in each subsequent two-year period.

What remains open, per article 3 of Lei 23/2007 as amended by that law:

• €500,000 or more in units of Portuguese non-real-estate collective investment undertakings, with a maturity of at least five years at the time of investment and at least 60% of the investment in commercial companies with their seat in Portugal.
• €500,000 or more to set up a company with its seat in Portugal and create five permanent jobs, or to reinforce the capital of an existing one with five new permanent jobs or ten jobs kept, for at least three years.
• €500,000 or more in research by public or private scientific institutions, €250,000 or more in artistic production or the recovery of national cultural heritage, or the creation of at least ten jobs, as listed by AIMA, the immigration agency. Your lawyer confirms which route fits your case.

None of these may be directed, directly or indirectly, to real estate. That sentence is in the law itself.

Two changes around the permits matter for families. Lei 61/2025, in force since 23 October 2025, requires two years of valid residence before family reunification, but exempts minors, the co-parent of a minor and the family of investment-permit holders. And Lei Orgânica 1/2026, in force since 19 May 2026, raised the residence period for naturalisation to seven years for citizens of EU and Portuguese-speaking countries and ten years for everyone else, for applications filed after that date. The “citizenship after five years” line still on many vendor pages is out of date.

Your banks: KYC, CRS and reporting after the move

The least visible of the moving to Portugal tax implications sits in your banks’ compliance files. Under the OECD Common Reporting Standard, each bank reports your accounts to the tax authority of the country where you are resident. Change the residence and you change who receives the data. Portugal applies the standard through Decreto-Lei 61/2013, as amended by Decreto-Lei 64/2016, which transposed the EU directive on automatic exchange of financial account information.

What follows from that:

• A new self-certification. A bank may rely on your self-certification only until it knows or has reason to know that it is wrong. The Tax Authority’s CRS guidance is explicit: Portuguese banks must tell everyone who signs a self-certification that they are obliged to report any change of circumstances. A move is the change.
• Entities, not just people. For a passive entity, such as most holding companies and many trusts, the bank identifies and reports the controlling persons by their residence. When one family member moves, the reporting on every entity they control changes too.
• The Portuguese account. A Portuguese bank must obtain your self-certification when the account is opened. The Tax Authority’s FAQ allows up to 90 days, where expressly provided, only to validate it, not to collect it.

In practice, the order that works:

1. Origin-country private banks first: a written notice of the move and its date, then the new self-certification once the date is real.
2. Entity accounts next, one controlling-person form per entity per bank.
3. The new Portuguese account last, opened with the residence documents already in hand.
4. Expect re-papering: refreshed KYC and new source-of-wealth questions. Keep every letter and signed form in one file; the tax advisor will need it at the first filing.

After the move, the family needs one view of everything in euros. That is a reporting problem, not a tax one, and we cover it in consolidated reporting across multiple banks. Keeping the bank letters, forms and statements in one place is the kind of work our administration and back office service exists for.

Entities you own abroad: review before the residence date

Once the owner is Portuguese resident, the income, distributions and sale gains of every entity they own are seen from Portugal. And the entity itself can change residence. Article 2 of the IRC Code treats as resident any entity with its seat or its effective management in Portugal. Take a holding company, a company that exists to own shares in other companies: incorporated abroad but run from Lisbon, it is a question for your tax advisor before you arrive, not after. Entities in jurisdictions on Portugal’s list of more favourable tax regimes, approved by ministerial order, attract different rules; which ones apply is to confirm with your tax advisor.

What the review covers, entity by entity:

• Who owns what, directly and through other entities.
• Where each board meets, who signs and from where.
• What each entity distributes, and when the next distribution or sale falls relative to the residence date.
• Which trusts or foundations have a family member as settlor, protector or beneficiary.
• Which beneficial-ownership registers need updating after the move.

Who decides: the tax advisor in each country and the corporate lawyer. The coordinator prepares the map and the list of questions, so the advisors spend their hours on answers rather than on discovery. We have seen the opposite order in our own work: a developer asked to move to Dubai before anyone could say what his nine companies owned or owed, and the Portugal UAE double tax treaty meant the move would not have touched the tax on his Portuguese property anyway.

Coming from the UK, Spain or Brazil

The Portuguese side of the timeline is the same for everyone. The exit side is not.

From the UK

The moving to Portugal from UK requirements start with immigration: UK nationals are no longer EU citizens, so the EU registration route does not apply, and the lawyer chooses the residence visa or permit. On moving to Portugal from the UK, tax is the longer tail. HMRC’s statutory residence test decides each year whether you are still UK resident, through automatic overseas tests, automatic UK tests and a sufficient-ties test. Split-year treatment can divide the year of departure into a UK part and an overseas part, under specific cases such as starting full-time work abroad or joining a partner who has. Inheritance tax now follows residence, not domicile. Since 6 April 2025, you are a long-term UK resident if you have been UK resident for at least 10 of the last 20 tax years, and that status follows you after you leave for between three and ten years, depending on how long you lived in the UK. Your UK tax advisor confirms which years apply.

From Spain

Spanish citizens move as EU citizens: no visa, and the CRUE at the câmara municipal after three months. The tax exit is where the work is. Under article 9 of the Spanish income tax law, you remain Spanish resident if you spend more than 183 days in Spain in the year or if your main centre of economic activities or interests is there, and you are presumed resident if your spouse and minor children stay in Spain. Article 95 bis taxes unrealised gains on shareholdings when you leave, if you were resident for at least 10 of the last 15 years and the shares are worth more than €4 million, or more than €1 million for a holding above 25%. A separate regime applies to moves to another EU or EEA state, Portugal included; your Spanish tax advisor confirms how it applies. The change of address goes to the Agencia Tributaria on modelo 030 within three months.

From Brazil

Brazil asks for two separate filings. The Comunicação de Saída Definitiva do País goes to the Receita Federal from the date of departure until the last day of February of the following year. The Declaração de Saída Definitiva do País is then filed in the following year, within the normal annual deadline, and is required whether or not the Comunicação was filed. Ask each Brazilian bank in writing how your accounts will be treated once you are non-resident, and keep the answer with the exit file. Treaty questions between Brazil and Portugal belong to the tax advisors in both countries.

Where a written second opinion fits

Before the first row of the timeline, an outside reading helps: is the entity map complete, is every bank on the list, does the calendar put each decision on the right side of the residence date? We read the file, we do not sell the move, and we are paid by the family, and only by the family. The fastest first step is a written second opinion.

Questions we hear

Can I still get the NHR in Portugal?

No, not as a new resident. Lei 82/2023, the 2024 State Budget, revoked the NHR from 1 January 2024, with a transitional rule for people who became resident by 31 December 2024 and met its conditions. IFICI now covers qualifying professional income for new residents. Whether you qualify is your tax advisor’s decision.

Is the Golden Visa real-estate route closed?

Yes. Lei 56/2023 stopped new applications under the property routes from 7 October 2023. The fund, research, culture and job-creation routes remain, and none of them may be directed, directly or indirectly, to real estate. Permits granted under the old rules can still be renewed, with a minimum stay of seven days in the first year.

What should I tell my bank when I move to Portugal?

Your new tax residence and the date it starts, through a new CRS self-certification for each account you hold and for each entity whose accounts list you as a controlling person. Expect a KYC refresh and new source-of-wealth questions. Send the notices in writing, keep copies in one file, and tell the origin-country banks first.

Do I need a NIF before moving to Portugal?

In practice, yes. The bank account, the lease and the residence application all ask for one. A non-resident can request a NIF at a tax office or online through e-balcão via a legal representative with a power of attorney. A fiscal representative is no longer mandatory if you adhere to electronic notifications.

Does moving to Portugal change how my foreign companies are taxed?

It can. Once you are Portuguese resident, distributions and gains from your companies are seen from Portugal, and a company whose effective management sits in Portugal can itself be treated as Portuguese resident under the IRC Code. Review each entity before the residence date with a tax advisor in each country.

How long before moving to Portugal should a family start planning?

About twelve months for a family with companies, trusts or several banks. Entity decisions belong before the residence date, exit filings follow the origin country’s calendar, and residence permits and bank re-papering each take months. Starting a year out lets these clocks run in the right order instead of colliding.

Sources

All pages opened and checked on 6 October 2026.

• Diário da República, “Lei n.º 56/2023, de 6 de outubro” (Mais Habitação), 6 October 2023. Supports: no new property-route ARI applications from entry into force (art. 42), pending applications kept (art. 43), renewals and conversion with 7/14-day minimum stay (art. 42 n.º 5), remaining €500,000 fund and company routes and the real-estate exclusion (art. 44, amending art. 3 of Lei 23/2007), entry into force the day after publication (art. 55). files.diariodarepublica.pt
• AIMA, Agência para a Integração, Migrações e Asilo, “Autorização de Residência para Investimento – Art. 90.º-A” (undated page). Supports: remaining routes (ten jobs; €500,000 research; €250,000 culture; €500,000 funds; €500,000 company with five jobs), the real-estate exclusion, minimum stay of 7 days in the first year and 14 days in later years. aima.gov.pt
• Autoridade Tributária e Aduaneira, binding ruling (ficha doutrinária), process 26609, decision of 29 January 2025. Supports: NHR revoked from 1 January 2024 by Lei 82/2023 of 29 December; transitional rule in art. 236 for residents by 31 December 2024 with steps started in 2023. info.portaldasfinancas.gov.pt
• Portal das Finanças, IFICI FAQ. Supports: art. 58.º-A EBF, 20% rate on category A and B income from eligible activities, ten consecutive years, five-year non-residence condition, exclusion of former NHR beneficiaries, registration by 15 January of the following year. info.portaldasfinancas.gov.pt
• Diário da República, “Portaria n.º 52-A/2025/1, de 25 de fevereiro” (copy hosted by IAPMEI). Supports: amendment of Portaria 352/2024/1 of 23 December regulating art. 58.º-A EBF; registrations on the Portal das Finanças. iapmei.pt
• Portal das Finanças, Código do IRS, article 16. Supports: 183-day and habitual-residence tests; residence from the first day of presence. info.portaldasfinancas.gov.pt
• Portal das Finanças, Código do IRS, article 60. Supports: IRS return filed from 1 April to 30 June. info.portaldasfinancas.gov.pt
• Portal das Finanças, Código do IRC, article 2. Supports: entities with seat or effective management in Portugal are resident. info.portaldasfinancas.gov.pt
• Portal das Finanças, FAQ on NIF for foreign citizens. Supports: NIF requested at a tax office or via e-balcão by a legal representative with a power of attorney; legal representative distinct from fiscal representative. info.portaldasfinancas.gov.pt
• Portal das Finanças, FAQs on the fiscal representative of non-residents and electronic notifications. Supports: Decreto-Lei 44/2022 of 8 July amended art. 19 LGT to waive the fiscal representative for taxpayers who adhere to electronic notifications. info.portaldasfinancas.gov.pt
• Autoridade Tributária e Aduaneira / OECD, “Perguntas Frequentes relacionadas com o CRS”, last updated May 2024. Supports: self-certification reliance and change of circumstances; duty to notify changes (art. 11 n.º 4, Annex I, Decreto-Lei 61/2013); controlling persons of passive entities; self-certification obtained at account opening, with up to 90 days to validate where expressly provided (FAQ 22). info.portaldasfinancas.gov.pt
• Diário da República, “Decreto-Lei n.º 64/2016, de 11 de outubro”. Supports: automatic exchange of financial account information and due-diligence rules for financial institutions, transposing Directive 2014/107/EU. diariodarepublica.pt
• Diário da República, “Lei n.º 61/2025, de 22 de outubro”. Supports: two-year residence condition for family reunification (art. 98 n.º 1) and its exceptions, including families of art. 90.º-A permit holders (art. 98 n.º 3); entry into force the day after publication. files.diariodarepublica.pt
• Ministério da Justiça, “Lei da Nacionalidade: novas regras entram em vigor a 19 de maio”, 19 May 2026. Supports: Lei Orgânica 1/2026 of 18 May; seven years for CPLP and EU nationals, ten years for others; applies to applications filed after entry into force. justica.gov.pt
• Câmara Municipal do Porto, “Certificado de Registo do Cidadão da União Europeia (CRUE)”. Supports: CRUE requested at the municipality within 30 days after three months in Portugal (Lei 37/2006). portaldomunicipe.cm-porto.pt
• HMRC, “Guidance note for Statutory Residence Test (SRT): RDR3”, updated 11 June 2026. Supports: automatic overseas, automatic UK and sufficient-ties tests; split-year treatment on departure. gov.uk
• HMRC, Inheritance Tax Manual IHTM47001 and IHTM47020, updated 7 April 2026. Supports: long-term UK residence (10 of the last 20 tax years) from 6 April 2025; tail of three to ten years after leaving. gov.uk · gov.uk
• Boletín Oficial del Estado, Ley 35/2006 del IRPF, consolidated text updated 2 October 2026. Supports: art. 9 residence tests and family presumption; art. 95 bis exit tax (10 of 15 years, €4 million, or 25% and €1 million) and the separate EU/EEA treatment. boe.es
• Agencia Tributaria, “Cómo comunicar el cambio de mi domicilio fiscal”, 24 September 2026. Supports: change of fiscal address on modelo 030 within three months. sede.agenciatributaria.gob.es
• Governo do Brasil, “Comunicar saída definitiva do País”, updated 21 July 2026. Supports: Comunicação de Saída Definitiva by the last day of February of the following year; Declaração de Saída Definitiva filed in the following year regardless. gov.br
• Portugal–UAE double tax convention, signed 17 January 2011, approved by Resolução da Assembleia da República n.º 47/2012, Article 13(1): gains from immovable property situated in the other State may be taxed in that State. Text on Portal das Finanças. Checked 2026-10-06.

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Pedro Souto is the founder of PWA — Private Wealth Advisory. He works with UHNW founders, families, and single-family offices to build an independent operating layer around complex wealth — combining markets, analytics, technology, and governance to turn fragmented advice into one coherent picture, and to make someone, finally, responsible for the whole of it.