Does Portugal have a Double Taxation Treaty with South Africa?

Yes, Portugal and South Africa have a Double Taxation Treaty (DTT) signed in 2000. This treaty prevents most double taxation by allocating taxing rights between the two countries and allowing foreign tax credits.

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South Africa Expats in Portugal — Tax Guide 2026

By Taxpert Editorial · Last reviewed: 26 April 2026

South Africa has a DTT with Portugal (2000). South African nationals (commonly moving via the D7 visa) face specific planning around South African financial emigration (now managed through SARS), retirement annuities (RAs), and the South African exit tax on shares.

Double Taxation Treaty: Yes (2000)
Tax relief mechanism: Treaty FTC

Key facts

SA-Portugal DTT signed 2000
SARS financial emigration: Formal cessation of SA tax residency through Exchange Control emigration process
SA exit tax: Deemed disposal of assets at FMV upon ceasing tax residency
RA (Retirement Annuity): South African RA is not a recognized pension structure in Portugal — withdrawals taxable as Cat. H
SARS withholding on SA-source income for non-residents: 20%–25% depending on income type
Dividends withholding tax (DWT): 20% on SA dividends → treaty reduces to 10%

Income type treatment

Employment

SA-source employment: SARS taxes. Portugal taxes worldwide; FTC for SARS withholding.

Pension

SA living annuity / RA drawdowns: Portugal Cat. H; SARS 18% lump-sum rate on RA withdrawals. FTC in Portugal. Government pension: Treaty allocates to South Africa.

Dividends

SA dividends: DWT 20% → treaty 10%. Portugal 28%. FTC.

Rental income

SA rental income: SARS taxes (property location). Portugal Cat. F; FTC.

Capital gains

SA shares exit tax triggered at departure. Future SA gains: SARS 18% effective rate for individuals. Portugal 28%. FTC.

Watch-outs for South Africa expats

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Financial emigration: The formal SARS process for exiting SA tax residency now requires a comprehensive disclosure of worldwide assets, tax compliance certificates, and SARB (SA Reserve Bank) approval for funds transfer. Allow 6–12 months.

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RA restrictions: South African law restricts RA withdrawal until age 55 (minimum). Moving to Portugal does not override this — you cannot access your RA until the SA age threshold, regardless of your Portuguese status.

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DWT refund: Unlike Switzerland, the full 20% SA DWT cannot all be claimed as FTC in Portugal — only the treaty-reduced 10% applies. The excess 10% must be reclaimed from SARS.

Recommended regimes

IFICI (for qualifying professionals)
Standard IRS (for retirees with SA pensions)

IFICI regime

20% flat rate for qualifying professionals

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NHR Legacy

For existing holders before Jan 2024

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This guide is for general information only. Tax laws in both South Africa and Portugal change frequently. Always consult a qualified tax advisor with expertise in both South Africa and Portuguese tax law before making tax decisions.