Does Portugal have a Double Taxation Treaty with Switzerland?

Yes, Portugal and Switzerland have a Double Taxation Treaty (DTT) signed in 1974. This treaty prevents most double taxation by allocating taxing rights between the two countries and allowing foreign tax credits.

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Switzerland Expats in Portugal — Tax Guide 2026

By Taxpert Editorial · Last reviewed: 26 April 2026

Switzerland has a long-standing DTT with Portugal (1974). Moving from Switzerland to Portugal involves navigating the Swiss pillar pension system (1st, 2nd, 3rd pillars), Swiss cantonal taxes, and — for non-Swiss nationals who were Swiss residents — potential treaty implications. Switzerland's lump-sum taxation for wealthy foreign residents has parallels with Portugal's special regimes.

Double Taxation Treaty: Yes (1974)
Tax relief mechanism: Treaty FTC

Key facts

Switzerland-Portugal DTT signed 1974
Swiss 2nd pillar (BVG/LPP) lump-sum or annuity: Taxable in Portugal on withdrawal
3rd pillar (pilier 3a): Lump-sum withdrawals taxable in Portugal as Cat. H
Swiss source tax (Quellensteuer): May apply to Swiss-source income even after departure
Cantonal taxes end at departure from the canton (formal Abmeldung required)
Swiss AHV/IV (1st pillar state pension): Treaty allocates taxing rights to Portugal as residence state

Income type treatment

Employment

Swiss-source employment (remote): Switzerland taxes under treaty Article 15. Portuguese IFICI for qualifying Portuguese-source roles. Source tax (Quellensteuer) on Swiss salary — FTC in Portugal.

Pension

AHV (1st pillar): Portugal has primary taxing rights as residence state. Switzerland withholds Quellensteuer — FTC applied. 2nd pillar (BVG) lump sum or annuity: Portugal taxes as Cat. H on withdrawal or annuity income.

Dividends

Swiss dividends: Switzerland withholds 35% at source (exceptionally high). Treaty reduces to 15%. Portugal 28%. FTC covers the treaty-reduced Swiss withholding. Note: The excess (35%-15%) must be reclaimed from Swiss authorities using Verrechnungssteuer (refund) process.

Rental income

Swiss rental income: Switzerland taxes (property location). Portugal taxes as Cat. F; FTC for Swiss tax.

Capital gains

Switzerland does not tax capital gains on securities for private investors (Kapitalgewinnsteuer is canton-dependent but generally not charged at federal level for private individuals). Portugal 28% on securities gains. Real estate: Swiss rules vary by canton.

Watch-outs for Switzerland expats

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Swiss Verrechnungssteuer (withholding tax): Switzerland applies a 35% WHT on dividends and interest — one of the highest globally. To claim the treaty-reduced 15% rate, file for refund of the excess 20% via Swiss authorities. This process can take 1–2 years.

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Formal Abmeldung: Formally deregister from your Swiss commune of residence. Without this, Switzerland may continue to charge cantonal taxes even after departure.

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2nd pillar early withdrawal: Moving outside the EU/EEA triggers the right to early lump-sum withdrawal of the 2nd pillar (BVG Freizügigkeitsguthaben). Switzerland withholds at a favorable rate. Portugal taxes this as Cat. H income — plan the timing relative to your IRS Jovem or IFICI regime.

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3rd pillar: Early withdrawal possible upon permanent emigration. Swiss tax applies at a reduced lump-sum rate. Portugal taxes upon receipt as Cat. H.

Recommended regimes

IFICI (for tech, financial, and research professionals)
Standard IRS (for retirees)

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 Switzerland and Portugal change frequently. Always consult a qualified tax advisor with expertise in both Switzerland and Portuguese tax law before making tax decisions.