Tax Law - Portugal
At Belzuz Advogados, our Tax Law Department provides high-level, strategic advisory services to both companies and individuals, ensuring full compliance with tax obligations while identifying opportunities for efficient tax optimization. In a complex and constantly evolving regulatory landscape, our team offers clarity, precision, and foresight.
With offices in Lisbon, Oporto, and Madrid, we deliver an international and integrated legal approach, enabling comprehensive support for cross-border operations and the efficient application of international tax frameworks.
If you are seeking a trusted partner with proven expertise and a forward-thinking mindset in tax matters, Belzuz Advogados can assist you in achieving effective, secure, and tailored legal solutions.
We have a team with deep knowledge of both domestic and international tax law, with an integrated legal approach, working across practice areas to provide complete and cohesive advice, bringing extensive experience across a wide range of tax matters, from international tax planning and cross-border structuring to tax due diligence in corporate transactions. We regularly assist clients with complex matters such as the taxation of crypto assets, transfer pricing, VAT and indirect taxes, and the implementation of employee incentive plans.
Our multidisciplinary expertise allows us to advise on both contentious and non-contentious issues, ensuring rigorous compliance while identifying opportunities for tax efficiency in Portugal and abroad.
Specialties
- Tax Consulting and Planning
- IRS
- Corporate and International Taxation
- Transfer Pricing
- Tax Litigation and Arbitration
- Tax Inspections
- Due Diligence and Tax Compliance
- International Tax Law and Double Taxation
- Digital Taxation and Cryptocurrencies
- Startups and Technology Companies
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Tax Advice on Indirect Taxes,
Consumption and Social Security - VAT
- Tax benefits and tax regimes
Tax consultancy and planning are essential to ensure an efficient tax structure in line with legal requirements. Belzuz Advogados assists companies and individuals in defining strategies that minimize risks and maximize tax benefits. Our services include the analysis and optimization of the tax obligations, advice on the application of tax incentives and special regimes, tax structuring for corporate restructuring and mergers and acquisitions. In addition, we provide support in adapting to constant legislative changes, ensuring that decisions are made safely and in compliance with applicable legislation.
Belzuz Advogados advises individuals on the analysis and tax optimization of their income, both in national and international operations. For clients wishing to change their residence to Portugal, we offer detailed advice, analysing the tax impacts of this change. In addition, we assist in the displacement of workers, ensuring an efficient tax structure that minimizes risks and maximizes tax benefits.
We advise on the preparation and planning of IRS tax returns with complex operations, from completion and submission to the settlement stage, ensuring compliance and timely fulfilment of the tax obligations. We also offer support in verifying the legality of assessments and in submitting claims or legal challenges if irregularities are identified.
Corporate and international taxation involves the efficient management of taxes applicable to companies’ national and global operations. Belzuz Advogados advises clients on the tax structuring of international businesses, ensuring compliance with local regulations and treaties to avoid double taxation. We work to define strategies for tax optimization, including the application of transfer pricing, ensuring that transactions between related entities are carried out in accordance with the arm’s length principle. We also provide support in the taxation of foreign investments, international corporate reorganisations and adaptation to European and global tax rules, reducing risks and promoting tax efficiency in an increasingly regulated environment.
Transfer pricing refers to the rules and practices used by companies to determine the values of transactions between companies within the same business group, transactions – linked transactions – must be carried out as if they were between independent entities, under the arm’s length principle, i.e. at market price, adopting one of five applicable methods, including the Comparable Market Price Method, the Cost Added Method, the Resale Price Method, the Transaction Profit Method and the Net Transaction Margin Method.
Commercial purchase and sale transactions, including those involving tangible or intangible assets, rights or services, even if carried out within the scope of any agreement, namely cost sharing and intra-group service provision, as well as financial transactions and corporate restructuring or reorganization operations, are considered to be tied transactions.
Belzuz Abogados can advise clients on the preparation and consolidation of the information to be provided to the Tax Authority regarding the transfer pricing dossier, either at the level of the global dossier – Master file, or at the level of the local dossier – Local file, or even at the level of the simplified dossier, if applicable, namely advising on the preparation of the Functional Analysis – which consists of a description of the functions performed, the risks assumed and the assets employed by the company in the normal development of its activity, as well as in the Preparation of the Economic Analysis(s) of Transfer Prices – in particular in the selection and justification of the most appropriate transfer pricing method or methods for the categories of operations under analysis, carrying out the respective research and documentation of comparable prices, operations or entities.
Belzuz Abogados can also advise the client on the three-yearly validation of the comparability studies presented in the transfer pricing dossier, provided that the facts and circumstances associated with the operations are not substantially altered, without prejudice to the annual updating of the financial data.
Tax litigation and arbitration are essential for defending taxpayers in tax disputes. Belzuz Advogados represents companies and individuals in administrative and judicial proceedings, from challenges to tax acts to appeals against undue tax assessments. We work to negotiate solutions with the tax authorities, minimizing financial impacts. Tax arbitration has emerged as an effective and speedy alternative for resolving tax disputes, avoiding the long delays of the courts. Our team combines experience and strategy to achieve the best results, ensuring rigorous and personalized follow-up at every stage of the process.
Tax inspections require a detailed understanding of tax regulations and a strategic approach. Belzuz Advogados supports companies and individuals during inspection procedures, preparing responses and documents, ensuring that all information provided is correct and complete, and representing our clients’ interests, ensuring that their rights and guarantees are respected.
We carry out a critical analysis of inspection reports to verify compliance with the formal requirements and the legal framework of the corrections proposed by the Tax Authority. We work on the preparation of defence strategies, contesting any errors or illegalities committed by the Tax Authority, and we provide support in regularizing the tax situation, as well as the possibility of reducing the fines imposed.
Due diligence and tax compliance are essential for risk mitigation and legal certainty for companies. Belzuz Advogados carries out detailed tax audits to identify tax contingencies in mergers, acquisitions and corporate restructurings. We implement compliance policies to ensure that companies act in accordance with tax regulations, preventing penalties and tax liabilities. We also advise on reviewing and improving internal tax reporting and payment processes, reducing exposure to tax risks and optimizing relations with the tax authorities. Our aim is to offer tax security and transparency to business operations.
Double taxation situations are complex issues that require an articulate knowledge of national and international legislation. Belzuz Advogados offers a full range of services for clients with any type of global presence, helping them to identify and prevent complex double taxation situations.
We analyse Double Taxation Conventions in order to prevent and resolve tax residency conflicts, and retroactively adjust your residency in Portugal when necessary, so that you can enjoy tax benefits or correct undue assessments.
We advise on the preparation and submission of Modelo 21-RFI to avoid withholding taxes in Portugal, as well as Modelo 24-RFI for the recovery of overpaid taxes, ensuring that all the benefits of the application of the Tax Conventions are reaped.
We also advise on the taxation of residents and non-residents in Portugal, for example in cases where there are capital gains on real estate in Portugal. In this context, we assist in the recovery of taxes paid in Portugal on the sale of real estate by non-residents until 2022, ensuring efficient tax management and compliance with current legislation.
Belzuz Advogados offers complete tax support for startups, fintechs and technology companies, from their incorporation to compliance with tax obligations. With a personalized approach, we help you choose the right tax regime and structure your company efficiently. We ensure that tax reporting and payment processes are carried out in accordance with legal requirements, minimizing tax risks. Our team also offers ongoing consultancy, adapting to the dynamic needs of the sector, promoting sustainable growth and tax compliance, with a focus on innovation and efficiency in tax management.
Our team offers specialized legal advice on all matters related to the establishment, modification, and management of horizontal property (condominium ownership), including residential buildings, real estate developments, and shopping centers.
We assist our clients in drafting condominium regulations, amending the title deed of horizontal property, defining, and limiting the rights of co-owners, and apportioning expenses related to common areas, such as maintenance costs, repair works, and shared services.
With extensive experience in resolving disputes in this area, we prepare rigorous legal opinions on the most complex and contentious matters and provide legal assistance during Condominium General Meetings, offering technical support and legal representation whenever necessary.
We also defend the interests of the condominium and co-owners in judicial and arbitral proceedings, ensuring effective action whenever out-of-court dispute resolution is not feasible.
Belzuz Advogados’ tax advice covers indirect taxes, excise duties and social security contributions. We help companies and individuals understand and manage their tax obligations in these areas, ensuring compliance and tax optimization. We analyse the implications of sales, service and consumption taxes, as well as provide guidance on social security contributions, ensuring that taxpayers avoid penalties. Our team offers practical solutions to reduce the tax burden and improve efficiency in the management of these taxes, contributing to the financial health of the company and the individual.
Value Added Tax is one of the most complex taxes and has the greatest impact on commercial operations. Belzuz Advogados has extensive experience in dealing with VAT issues, providing support in framing operations, ensuring that national, international and intra-community transactions comply with the applicable VAT regulations.
In this context, we advise on the correct identification of the location of transactions, ensuring compliance with VAT rules in different jurisdictions, as well as on the legislation applicable to ecommerce in distance sales (one-stop-shops, OSS, imported goods, IOSS).
We also provide advice on recovering overpaid VAT and clarifying doubts about the applicability of VAT exemptions and reduced rates.
In order to maintain Portugal as an attractive destination for companies, qualified professionals and foreign investors, there are a wide variety of tax benefits and regimes in place.
The Tax Incentive for Scientific Research and Innovation (IFICI) was created for individuals, replacing the Non-Habitual Resident (NHR) regime.
The IFICI aims to offer a competitive tax framework, encouraging highly qualified, entrepreneurial workers to come to the country. The main features of this scheme include:
- Reduced taxation on employment income: Application of a special rate on income earned by qualified professionals in Portugal.
- Incentives for investors and entrepreneurs: Tax benefits for foreigners setting up business or making investments in the country.
- Duration of scheme: Application of the scheme for a limited period, with the possibility of renewal subject to specific criteria.
Belzuz Advogados provides comprehensive advice on joining the IFICI, helping clients to understand the eligibility criteria, submit applications to the tax authorities and structure their assets efficiently to maximize the benefits of this scheme.
Companies, on the other hand, can benefit from several tax incentives and special schemes to reduce their tax burden and increase their competitiveness. Some of the main measures include:
- Investment Support Tax Regime (RFAI): Reduced taxation on profits reinvested in productive assets.
- Benefits for Research & Development (R&D) activities: Deduction of expenses for innovation and technological development.
- Incentives for Internationalization: Favourable tax regimes for companies that expand operations to foreign markets.
- Tax credits and deductions: Applicable to strategic sectors and companies that promote employment and sustainable development.
Our team of experts assists in identifying and applying these benefits, ensuring that companies maximize the tax opportunities available within the current legal framework.
Our Team

Female Senior Associate Lawyer
Rafaela Beire Cardoso

Female lawyer
Beatriz Pereira

Senior Lawyer
Miguel Paixão
