Taxation in Spain vs. Portugal: a practical comparison for Brazilians (2026)

Spain vs. Portugal: how income tax and the taxation of international income work

The choice between Portugal and Spain is often guided by language, cost of living, and professional opportunities. However, taxation is one of the factors that most directly affects the viability of the plan—especially for Brazilians with international income (freelancers, business partners, investors, and remote professionals).

In this article, I present an objective comparison of the main tax aspects for those considering living and working in Portugal or Spain, focusing on tax residence, foreign income, special regimes, and the risk of double taxation.

Note: Tax rules vary depending on visa type, family composition, source of income, and asset structure. This content is informational and does not replace an individualized analysis.

1) Tax residence: the starting point (and what changes in practice)

The comparison between Portugal and Spain begins with a fundamental question: where will you be considered a tax resident? This determines (i) which income will be taxed, (ii) whether worldwide income must be reported, and (iii) how tax treaties apply.

In practice, it is common for individuals to “believe” they reside in one country while being deemed tax residents in another due to days of presence, center of vital interests, family ties, available housing, employment, and similar factors. This mismatch is one of the main causes of tax audits and difficulties in proving tax residence during regularization procedures.

2) Portugal: IRS framework and special regimes

Portugal taxes individuals under IRS (Personal Income Tax), and for Brazilians the analysis usually involves:

• classification of income (employment, self-employment, investments);

• treatment of foreign-source income;

• and special regimes that may reduce the tax burden, when applicable.

2.1 IFICI (Portugal): tax incentive for research and innovation

Portugal introduced the IFICI, provided for in Article 58-A of the Tax Benefits Statute, establishing a special 20% IRS rate on income from Categories A and B derived from eligible activities, according to applicable regulations.

In practice, IFICI is relevant for qualified profiles—especially those engaged in innovation, technology, or scientific activities—subject to eligibility criteria and formal registration procedures. Eligibility and documentary evidence are critical.

2.2 “End of the NHR” and transitional rules

The former Non-Habitual Resident (NHR) regime was revoked with effect from January 1, 2024, with transitional rules applicable to specific situations, depending on the individual’s circumstances and relevant dates.

To learn more about taxation in Portugal, read this article.

3) Spain: IRPF framework and the special impatriates regime (Beckham Law)

In Spain, individual income tax is levied under the IRPF (Personal Income Tax), and one of the most searched topics among foreigners is the special impatriates regime (commonly referred to as the “Beckham Law”).

The Spanish Tax Agency (AEAT) describes the regime as optional, with specific requirements, including not having been a Spanish tax resident for a defined prior period and relocation under certain legally established circumstances.

Why does this matter for Brazilians?

Because when the regime applies, the taxation logic may change significantly compared to the general IRPF system—particularly for individuals relocating with an employment contract, executive position, or corporate transfer, and whose income is primarily sourced in Spain.

To learn more about taxation in Spain, read this article.

4) Foreign income: where the risk lies

For Brazilians with international income, the critical points include:

• active income (remote services, management fees, employment income);

• passive income (dividends, interest, rental income, capital gains);

• structure (individual, company, holdings, offshore entities, funds, trusts, etc.);

• compliance (tax filings, proof of tax residence, banking and tax documentation).

The treatment of foreign income varies case by case and is precisely where proper tax planning prevents (i) double taxation, (ii) improper withholding at source, and (iii) documentary inconsistencies.

5) Treaties: Brazil x Portugal and Brazil x Spain

Brazil has double taxation treaties with both Portugal and Spain, which may be relevant for mitigating double taxation and organizing how tax residence is proven in each country.

Important: a tax treaty does not grant “automatic exemption.” Its application depends on:

• properly documented tax residence;

• correct income characterization;

• and full formal compliance (documents and deadlines).

6) Conclusion: how to choose between Portugal and Spain from a tax perspective

There is no universally “better” country. There is only the best scenario for your specific profile.

In general terms:

• Portugal is often chosen by Brazilians due to language, lifestyle infrastructure, and the possibility of specific regimes (when eligible), such as IFICI.

• Spain is highly sought after for professional opportunities and, in some cases, for the Beckham Law regime (when applicable).

f you are a Brazilian living abroad (or a foreigner in Brazil) and wish to engage professional legal services to structure your tax residence and international income safely, we are a law firm specialized in this area. Please contact us at contato@trpuppioadvocacia.com.br or via WhatsApp.

FAQ (SEO)

1. Which country has “lower taxes”: Portugal or Spain?

It depends on your income profile, tax residence, and eligibility for special regimes.

2. Is IFICI in Portugal automatic?

No. It requires eligible activities and compliance with formal registration procedures.

3. Does Spain have a special regime for foreigners?

Yes. The Beckham Law regime applies under specific requirements.

4. Are there tax treaties between Brazil and Portugal and Spain?

Yes. Brazil has treaties in force with both countries.