Family office in Portugal: an EU holding base with falling corporate tax, no wealth tax and a residence pathway

Portuguese law contains no family office category. The question is whether the office carries out regulated activities for third parties. Investment advice, portfolio management and order handling are reserved to investment firms under the Código dos Valores Mobiliários and the Regime Jurídico das Empresas de Investimento approved by Decreto-Lei 109-H/2021, while the management of collective investment undertakings is governed by the Regime da Gestão de Ativos (RGA, Decreto-Lei 27/2023) and CMVM Regulation 7/2023. All are supervised by the Comissão do Mercado de Valores Mobiliários (CMVM). A single-family office that manages the family's own holding and portfolio through its own employees, without holding itself out to the public, generally falls outside these regimes; a multi-family office serving unrelated families needs authorisation, and any lending or payment activity raises Banco de Portugal questions.

The usual architecture is a Portuguese holding company, a sociedade anónima or Lda, that owns operating businesses, real estate companies and a securities portfolio. The SGPS form still exists, but since the 2014 corporate tax reform its tax advantages have been replaced by a general participation exemption: under Articles 51 and 51-C of the IRC Code, dividends and gains on holdings of at least 10% held for 12 months are exempt, provided the subsidiary is subject to corporate tax and is not resident in a listed low-tax jurisdiction. Legislation approved by Parliament on 17 October 2025 and promulgated on 3 November 2025 reduces the general IRC rate to 19% for 2026, 18% for 2027 and 17% for 2028, with 15% on the first EUR 50,000 for SMEs; municipal and state surcharges still apply to larger profits. For illiquid investments and co-investment with friends or other families, the RGA offers alternative investment funds and venture capital vehicles managed by an authorised or registered manager.

For the family, Portugal has no annual wealth tax, although the additional municipal property tax (AIMI) applies to high-value Portuguese real estate. Gratuitous transfers on death or by gift are subject to stamp duty at 10%, but spouses, unmarried partners, descendants and ascendants are exempt, which makes intra-family succession of a Portuguese holding comparatively simple. Portugal has no domestic trust law and private foundations under the Framework Law on Foundations (Lei 24/2012) must serve social-interest purposes, so families combine the holding with shareholder agreements, a family charter, wills that respect forced heirship and, where appropriate, foreign trusts or foundations; trusts can be constituted in Portuguese law only within the Madeira free trade zone.

The non-habitual resident regime closed to new entrants at the end of 2023. Its successor, the tax incentive for scientific research and innovation (IFICI, Article 58-A of the Tax Benefits Statute and Portaria 352/2024), taxes qualifying employment and business income at 20% for ten years and largely exempts foreign-source income, but it is activity-based: a family office role qualifies only if the position and entity fall within the listed categories, so it is not an automatic route for family members. Residence for non-EU families runs through the Residence Permit for Investment (ARI) under Law 23/2007 as amended by Law 56/2023, where property no longer qualifies but a EUR 500,000 subscription to qualifying non-real-estate funds does; since Organic Law 1/2026, citizenship generally requires ten years of legal residence.