Family Office in Portugal: Rules, Costs and Tax in 2026
Portugal has no family office regime: under the Securities Code only authorised financial intermediaries may manage portfolios for others on a professional basis, and services provided only within a group are exempt. Residents pay income tax of up to 48% plus a solidarity surcharge of up to 5%, companies pay 19% corporate tax in 2026 (17% from 2028), and the spouse, descendants and ascendants are exempt from the 10% stamp duty on inheritances and gifts. The Golden Visa (residence permit for investment activity, ARI) is open in 2026 through EUR 500,000 in Portuguese non-real estate funds or in a company with jobs, among other routes, but three routes were repealed by Law 56/2023 of October 2023 and no qualifying investment may go into real estate, and since 19 May 2026 naturalisation needs 10 years of legal residence for nationals of countries outside the EU and the Portuguese-speaking community. [1, 2, 3, 4, 5, 6, 7, 8, 9]
Best for: Families who want an EU residence permit through a EUR 500,000 investment in Portuguese non-real estate funds or in a company with five permanent jobs, with only 7 days in Portugal in the first year, and who accept full Portuguese income tax if they become resident.
At a glance
| Licence | No family office regime; managing portfolios for others professionally needs authorisation |
|---|---|
| Minimum wealth | No wealth minimum in the Securities Code rules checked; no family office regime |
| Who counts as family | No family definition found; only group companies exempt (article 289(3)(b)) |
| Serving several families | No MFO licence; must be an authorised credit institution or investment firm (CMVM) |
| Law and courts | Securities Code and CMVM; national tax codes (AT); lower IRC in Azores and Madeira |
| Substance | No family office rule found; economic substance test for the dividend exemption |
| Holding vehicles | Commercial companies incl. single-member Lda; Portuguese funds; trusts not checked |
| Corporate tax | IRC 19% (2026), 18% (2027), 17% from 2028, plus 3% to 9% state surcharge |
| Family office tax | No FO regime; dividends on 10% stakes held a year exempt, not if payer listed (UAE is) |
| Personal income tax | 48% above EUR 86,634 plus 2.5% to 5% surcharge (2026); 28% capital income; IFICI 20% |
| Inheritance tax | 10% stamp duty; spouse, descendants, ascendants exempt, not from 0.8% on real estate gifts |
| Wills and succession | Forced heirship: half to two thirds reserved for spouse, children or spouse with parents |
| Residence | Golden Visa open: EUR 500,000 in funds or a company with 5 jobs; 7 days in year one |
| Time to set up | No official figure found |
| Official fees | No official figure found |
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Licence and who qualifies
How is a family office licensed in Portugal?
No family office licence, registration or exemption was found. Article 289(2) of the Securities Code says only financial intermediaries may carry out financial intermediation activities on a professional basis ('a título profissional'), portfolio management for others ('gestão de carteiras por conta de outrem') is an investment service under article 290(1)(c), and financial intermediaries are credit institutions and investment firms authorised to carry on such activities in Portugal (article 293(1)). Article 289(3)(b) excludes persons who provide investment services only to their parent company, its other subsidiaries or their own subsidiaries; no family exemption and no CMVM or Banco de Portugal statement on an office that manages one family's assets were found (the CMVM website could not be opened). [1, 11]
What is the minimum wealth for a family office in Portugal?
No minimum family wealth in the rules checked: the Securities Code's authorisation rule and group exemption (articles 289, 290 and 293) turn on the activity and on who is served, not on wealth, and there is no family office regime. The EUR 250,000 and EUR 500,000 amounts in Portuguese law are Golden Visa investment thresholds, not family office tests (see residency). [1, 12]
Who counts as family?
No definition of a family for family office purposes was found. The only exemption found covers services provided exclusively within a group: to the provider's parent company, the parent's other subsidiaries or the provider's own subsidiaries (article 289(3)(b) of the Securities Code), which covers group companies, not family members as such. [1]
Can one office serve several families?
No dedicated multi-family office licence was found. An office that manages portfolios for other families on a professional basis carries on an investment service (article 290(1)(c) of the Securities Code) reserved to financial intermediaries, that is, credit institutions and investment firms authorised to carry it on in Portugal (articles 289(2) and 293(1)). The Investment Firms Regime (Decree-Law 109-H/2021, last amended by Decree-Law 171/2026) created a single type of investment firm and concentrates their supervision in the CMVM; its articles on initial capital and authorisation were not read. [1, 11]
Law, substance and vehicles
Which law and courts apply?
Portuguese law is codified: investment services are governed by the Securities Code (Código dos Valores Mobiliários), last amended by Decree-Law 171/2026 of 26 August 2026 to transpose EU measures, and investment firms are supervised by the Securities Market Commission (CMVM). Taxes are set in national codes administered by the Tax and Customs Authority (AT), with lower corporate tax rates in the Autonomous Regions of the Azores and Madeira, and residence permits are granted by the Agency for Integration, Migration and Asylum (AIMA). [1, 7, 11, 13, 14]
What substance is required?
No office, staff or spending rule for a single family office was found. For a family holding company, the dividend exemption does not apply to an arrangement, or series of arrangements, that is not genuine because it was not put in place for valid economic reasons and does not reflect economic substance, where a main purpose is a tax advantage (article 51(13) and (14) CIRC). The Golden Visa company route requires five permanent jobs, or, for a capital increase in an existing company, five new permanent jobs or ten jobs kept, including five permanent ones. [8, 15]
Which holding vehicles are available?
The sources opened refer to commercial companies (sociedades comerciais) with their registered office in Portugal, including the single-member private limited company (sociedade unipessoal por quotas), which a Golden Visa investor may use to hold the investment, and to Portuguese collective investment undertakings (funds), used for the Golden Visa fund route. Foundations, trusts and partnerships were not checked in official sources. [7, 8, 16]
Tax
What is the corporate tax rate?
Corporate income tax (IRC) is 19% for tax periods starting in 2026, 18% in 2027 and 17% from 1 January 2028 (article 87 CIRC with article 3 of Law 64/2025 of 7 November 2025); from 2026, small and medium-sized enterprises and small mid caps whose main activity is agricultural, commercial or industrial pay 15% on the first EUR 50,000 of taxable profit. A state surcharge (derrama estadual) adds 3% on taxable profit from EUR 1.5 million to EUR 7.5 million, 5% from EUR 7.5 million to EUR 35 million and 9% above EUR 35 million (AT rates brochure for 2025), and the Azores and Madeira apply lower rates (14% general rate in 2025); the municipal surcharge (derrama municipal) was not checked. A family holding company pays these ordinary taxes, with the dividend relief set out under family office tax. [4, 14]
Are there tax incentives for family offices?
No tax regime for family offices was found. Dividends and distributed reserves received by a Portuguese company are left out of its taxable profit if it has held at least 10% of the capital or voting rights, directly or indirectly, without interruption for one year (or keeps the stake until a year is complete), it is not under the tax transparency regime, and the paying company is subject to a corporate tax at a statutory rate of at least 60% of the IRC rate and is not resident in a jurisdiction with a clearly more favourable tax regime on the list approved by ministerial order (article 51(1) CIRC). The United Arab Emirates is item 22 on that list in 2026 (Portaria 150/2004 as published by the AT, last amended by Portaria 292/2025/1, which removed only Hong Kong, Liechtenstein and Uruguay from 1 January 2026). Gains on shares are dealt with in a separate article (51-C CIRC), whose conditions were not read. [15, 17, 18, 19]
Is there personal income tax?
Residents pay personal income tax (IRS). For 2026 the general scale (article 68 CIRS, as set by the 2026 State Budget Law 73-A/2025) runs from 12.5% to 48% on taxable income above EUR 86,634, and a solidarity surcharge adds 2.5% on taxable income from EUR 80,000 to EUR 250,000 and 5% above EUR 250,000 (article 68-A), so the top marginal rate is 53% (our calculation); the AT's rates brochure for 2025 gives 28% for Portuguese capital income and securities income and for the net balance of capital gains. People who were not resident in any of the previous five years and work in a qualifying activity (research, qualified jobs, highly qualified professions and board roles in qualifying companies, certified start-ups) can register for IFICI by 15 January of the year after they become resident: 20% on employment and business income from that activity for 10 consecutive years, and foreign income in categories A, B, E, F and G exempt, except income paid by entities in jurisdictions on the list of clearly more favourable tax regimes, taxed at 35% (the AT's FAQ example: dividends from a Dubai company, because the United Arab Emirates is such a jurisdiction), while pensions (category H) are not exempt. Shareholders do not qualify merely as shareholders, and anyone who benefits or has benefited from the non-habitual resident (NHR) regime is excluded. NHR itself was repealed as of 1 January 2024, the AT says: it continues for people already registered on that date, and a transitional rule let those who became resident by 31 December 2024 apply if they could show one of the listed steps taken by the end of 2023, such as a job contract or a residence visa application by 31 December 2023 or a lease or school enrolment by 10 October 2023; benefits under that rule end with the 10th year counted from 2024. [2, 3, 14, 17, 20, 21, 22]
Is there inheritance or estate tax?
No separate inheritance tax was found: gratuitous transfers, including on death, are charged to stamp duty (Imposto do Selo) at 10% (item 1.2 of the General Table, AT rates brochure for 2025). The spouse or de facto partner, descendants and ascendants are exempt from this 10% (article 6(1)(e) of the Stamp Duty Code) but must still report the transfer. The AT says this exemption covers only item 1.2 and not item 1.1, which the AT's brochure describes as 0.8% on onerous acquisitions and donations of real estate; that description does not mention transfers on death, and no source opened says whether inherited real estate pays the 0.8%. The exemption does not extend to other beneficiaries, such as siblings, nephews and nieces or unrelated people. [5, 14, 23, 24]
Succession and residence
How do wills and succession work?
Portugal has forced heirship: the compulsory heirs are the spouse, descendants and ascendants, part of the estate (the legítima) must pass to them, and only the rest (the available portion) can be left freely, so the whole estate cannot be left to someone who is not a compulsory heir (article 2156 of the Civil Code, as described on the European e-Justice Portal, updated 26 June 2025). The reserved share is half of the estate for a spouse alone, two thirds for a spouse with children, half for one child or two thirds for two or more children without a spouse, and two thirds for a spouse with ascendants; the portal does not give the share for parents alone. Wills are made before a notary as public or closed wills, and joint wills are not allowed. [25]
Can the family get residence?
The Golden Visa, a residence permit for investment activity (ARI) under article 3(1)(d) of Law 23/2007, is open in 2026. The investment must as a rule be kept for at least five years and can be: EUR 500,000 in units of Portuguese non-real estate investment funds with at least five years to maturity at the time of investment and at least 60% invested in companies based in Portugal; EUR 500,000 to set up a company based in Portugal with five permanent jobs, or to increase an existing company's capital with five new permanent jobs or ten jobs kept (five permanent) for at least three years; EUR 500,000 in research; EUR 250,000 for artistic production or national cultural heritage; or creating 10 jobs. Article 3(2) allows the 10 jobs and the research, arts and heritage amounts to be up to 20% lower in low-density areas. Law 56/2023 of 6 October 2023 repealed three routes (sub-paragraphs i, iii and iv), and no qualifying investment may go directly or indirectly into real estate. Holders must spend 7 days in Portugal, consecutive or not, in the first year and 14 days in each later two-year period (SEF renewal guidance). AIMA lists as family members who can join the spouse, children under 18, dependent unmarried children aged 18 to 25 who are studying, dependent parents of the holder or spouse, and minor siblings under the holder's guardianship, and since 23 October 2025 (Law 61/2025) family members of ARI holders are exempt from the two-year wait for family reunification. Since 19 May 2026 (Organic Law 1/2026) naturalisation needs 10 years of legal residence, or 7 for nationals of EU and Portuguese-speaking (CPLP) countries; Observador reports the old rule was five years, and applications pending on 19 May 2026 follow the old law. The permit's length and renewals, permanent residence and the thresholds of the passive-income (D7) and digital nomad visas were not confirmed in official sources. [6, 7, 8, 9, 10, 12, 16, 26, 27, 28, 29]
Time and fees
How long does set-up take?
Not found in official sources.
What are the official fees?
Not found in official sources: the AIMA fee table for the Golden Visa and the official company registration fees could not be opened. AIMA says Golden Visa application fees have been paid at the in-person appointment since 15 January 2025. [6]
Pros and cons
Pros
- The Golden Visa is open in 2026 through EUR 500,000 in Portuguese non-real estate funds, EUR 500,000 in a company with five permanent jobs or EUR 250,000 for arts or heritage, with 7 days in Portugal in the first year and 14 days in each later two-year period.
- The spouse or de facto partner, descendants and ascendants are exempt from the 10% stamp duty on inheritances and gifts.
- Corporate tax falls from 19% in 2026 to 17% from 2028, and a family holding company is exempt on dividends from stakes of at least 10% held for a year if the payer is taxed at a statutory rate of at least 60% of the IRC rate and is not in a listed jurisdiction (the UAE is listed).
Cons
- Residents pay income tax of up to 48% plus a 2.5% to 5% solidarity surcharge and 28% on capital income; the 20% IFICI rate is only for qualifying jobs, not for shareholders as such, and IFICI holders pay 35% on foreign income paid by entities in listed jurisdictions such as the UAE.
- Since 19 May 2026 naturalisation needs 10 years of legal residence for nationals of countries outside the EU and the Portuguese-speaking community, instead of five.
- There is no family office regime or official guidance on one: managing portfolios for others professionally needs authorisation as a financial intermediary, and the only exemption found is for group companies.
