For many expats and entrepreneurs, maintaining or managing a foreign company while living in Portugal seems straightforward — but Portugal’s corporate tax rules can make things more complex than expected.

Key Point:

Unlike some countries that rely heavily on the “Place of Effective Management” (POEM) as a tie-breaker rule, Portugal uses “effective management” as a primary test for determining corporate tax residency.

Here’s what that means:

• 
  
• 
  
• 🏢 Head Office: This refers to the company’s registered or legal office — where it’s incorporated.
• 
  
• 
  
• 
  
• 🧭 Effective Management: This is where the real decisions are made — strategic, commercial, and operational.
• 
  
• 
  

If the Portuguese tax authorities determine that those key decisions are being made while you’re in Portugal, your company could be treated as Portuguese tax resident, even if it’s registered abroad.

The consequence:

That company’s worldwide income could become subject to Portuguese corporate tax.

In short:

Portugal treats the “effective management” rule as a central factor in deciding corporate tax residency — not just a secondary test. If you manage an offshore company while living in Portugal, professional tax advice is essential to avoid unexpected liabilities.