Tax residence in Portugal for Singapore taxpayers

Portugal treats you as resident with more than 183 days in any 12-month period beginning or ending in the year, or with a home there that you intend to keep and occupy as your habitual residence; the year of arrival or departure is split. Singapore decides your status for the whole calendar year. If both countries claim you, Art. 4(2) of the Portugal–Singapore Agreement decides; salary follows a 183-day rule over any twelve-month period (Art. 15(2)).

Check your status: Singapore and Portugal

Free, no sign-up, about 3 minutes. Conclusion under Singapore's Income Tax Act 1947, compared with the law of Portugal and the tax treaty (DTA).

When Portugal treats you as a tax resident

Portugal counts days over any 12-month period that begins or ends in the year concerned — not only the calendar year — and you must exceed 183 days (184 or more). A day counts if it includes an overnight stay in Portugal, even if you were there only part of the day.

With 183 days or fewer you are still resident if, on any day of that 12-month period, you had a home in Portugal in conditions suggesting a current intention to keep and occupy it as your habitual residence. A holiday or second home, or a home you plan to use only after a future return, is not enough; the courts look at where you actually live and have your family, work and economic ties.

You stayed in Portugal more than 183 days (counting every day with an overnight stay) in a 12-month period beginning or ending in this year — you are a Portuguese tax resident (art. 16(1)(a) CIRS) and owe IRS on your worldwide income. In the year you arrive you are resident from the first day of your stay (from 1 January if you were resident on any day of the previous year); in the year you leave, until your last day in Portugal, unless art. 16(14) keeps you resident for the whole year.
You had a home in Portugal in conditions suggesting a current intention to keep and occupy it as your habitual residence — you are a Portuguese tax resident (art. 16(1)(b) CIRS) even with 183 days or fewer, from the first day of your stay. The conclusion depends on the facts: owning or renting a home is not enough without a current intention to live there.
You perform public functions or a public mission abroad in the service of the Portuguese State — you are a Portuguese tax resident (art. 16(1)(d) CIRS) regardless of the days spent in Portugal.
On 31 December you were a crew member of a ship or aircraft serving an entity resident, or with its seat or effective management, in Portugal — you are a Portuguese tax resident for that year (art. 16(1)(c) CIRS).

When you are a non-resident

183 days or fewer in every 12-month period, no home in Portugal kept as habitual residence, and no Portuguese public service or crew position — you are not a Portuguese tax resident. Portugal taxes only your Portuguese-source income, for example pay for work done in Portugal (25% final withholding) or rent from Portuguese property.
You did not exceed 183 days, but it is unclear whether your home in Portugal shows an intention to keep it as your habitual residence. The tax authority and courts decide this on the facts (where you actually live, your family, work and assets); if they find such an intention you are resident. Keep evidence of where you live, and update your address with the tax authority when you leave.

Where the rules of Portugal clash with Singapore tax rules

Collision: more than 183 days in Portugal while still resident in Singapore. Portugal treats you as resident because you spent more than 183 days there in a 12-month period beginning or ending in the year; Singapore can treat you as resident for the same calendar year — as a citizen or Permanent Resident who normally lives in Singapore, under IRAS's two- or three-year rules, or with 183 days in Singapore in a calendar year that the Portuguese 12-month window only partly covers. Art. 4(2) of the Portugal–Singapore Agreement decides: permanent home; with a home in both countries, centre of vital interests; if that cannot be determined, or you have a permanent home in neither, habitual abode; then nationality; then mutual agreement.
Collision: a home kept in Portugal can make you resident without 183 days. Portugal treats you as resident if you had a Portuguese home in conditions suggesting a current intention to keep and occupy it as your habitual residence, even after a short stay. Under the treaty such a home will usually also be a «permanent home available to you»: if your only permanent home is in Portugal, Art. 4(2)(a) points to Portugal; if you also have a permanent home in Singapore, the centre of vital interests decides — family, work, assets and social ties. A holiday home, or a family home in Portugal that you yourself only visit, does not make you resident in Portugal.

What else to know

Which treaty applies: the Portugal–Singapore Agreement (1999). The Agreement signed at Singapore in September 1999 (on 6 September according to the Diário da República, on 7 September according to IRAS) has been in force since 16 March 2001; it applies in Portugal from 1 January 2002 and in Singapore from Year of Assessment 2003. The Protocol of 28 May 2012 replaced only the exchange-of-information article; the MLI adds a principal purpose test and arbitration but does not change Article 4. The English text prevails in case of divergence. Residence tie-breaker: Art. 4(2) — permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement (Art. 26). Employment: Art. 15 (183 days in any twelve-month period commencing or ending in the calendar year); independent services: Art. 14; private pensions: Art. 18 — State of residence only; government service: Art. 19; limitation of relief (remittance basis): Art. 23; relief: Art. 24 — credit in both countries.
Calendar year in Singapore, a rolling 12 months in Portugal. Singapore decides your residence for the calendar year: 183 days or more of presence or employment, normal residence as a citizen or Permanent Resident, or IRAS's two- and three-year rules. Portugal makes you resident with more than 183 days in any 12-month period beginning or ending in the calendar year — a stay from July to June can make you resident in both calendar years — and every day that includes an overnight stay in Portugal counts, even if you were there only part of the day. The 183-day limit for salary in Art. 15(2)(a) of the Agreement uses any twelve month period commencing or ending in the calendar year concerned. Keep a day count for each of these periods.
How Singapore and Portugal relieve double taxation. If Singapore is your state of residence, Portuguese income is generally not taxed in Singapore — foreign-sourced income received by a resident individual is exempt (s. 13(7A)); where Singapore does tax it, the Portuguese tax paid is credited against the Singapore tax on that income (Art. 24(2)) — claim the foreign tax credit in your Singapore return. Under Art. 23, a Portuguese exemption or reduced rate under the Agreement on income that Singapore taxes only when remitted applies only to the amount remitted to or received in Singapore. If Portugal is your state of residence, Portugal deducts the income tax paid in Singapore, up to the Portuguese tax attributable to that income (Art. 24(1); art. 81 CIRS). Income that one country exempts under the Agreement can still be counted for the rate on your other income (Art. 24(3)).
Working in Portugal while resident in Singapore: the 183-day rule (Art. 15(2)). Pay for work physically done in Portugal is Portuguese-source income, taxed at a 25% final rate for non-residents. If Singapore is your treaty residence, Portugal does not tax it only if all three conditions of Art. 15(2) are met: not more than 183 days in Portugal in any twelve-month period commencing or ending in the calendar year concerned, an employer that is not resident in Portugal, and pay not borne by a Portuguese permanent establishment or fixed base. Otherwise Portugal taxes the pay for Portuguese work days; in Singapore such pay is foreign-sourced income, generally exempt for a resident individual (s. 13(7A)), and where Singapore does tax it the Portuguese tax is credited (Art. 24(2)). Self-employed professionals: Portugal may tax only income attributable to a fixed base regularly available in Portugal, or with a stay of 183 days or more within any twelve-month period (Art. 14(1)).
Portuguese State official posted abroad. If you perform public functions or a public mission abroad in the service of the Portuguese State — including as a Member of the European Parliament — Portugal treats you as resident whatever the days spent there (art. 16(1)(d) CIRS). If Singapore also treats you as resident, Art. 4(2) of the Agreement decides. Pay from the Portuguese State for services rendered to it is taxable only in Portugal, unless the services are rendered in Singapore and you are a Singapore resident who is a Singapore national or did not become resident in Singapore solely to render them (Art. 19(1)).
Pensions and government pay between Singapore and Portugal. Pensions for past employment are taxable only in your state of residence (Art. 18): a private pension from Singapore received while the Agreement makes you a resident of Portugal is taxed in Portugal at the progressive IRS rates — the IFICI regime covers only employment and business income. Salaries and pensions paid by Singapore, a political or administrative subdivision, a local authority or a statutory body for services rendered to it remain taxable only in Singapore, unless (for pay) the services are rendered in Portugal by a Portuguese resident who is a Portuguese national or did not become resident there solely to render them, or (for pensions) you are both resident in and a national of Portugal (Art. 19).
Year of moving: Portugal splits the year, Singapore does not. In the year you arrive, Portugal treats you as resident from the first day of your stay; in the year you leave, until your last day of presence (art. 16(3)–(4) CIRS), and you file a separate Portuguese return for each period. Two exceptions: if you spent more than 183 days in Portugal in the year of departure, you stay resident for the whole year unless you show that the income you earn after leaving is taxed in your new country of residence at a rate of at least 60% of the Portuguese rate — Singapore is outside the EU/EEA, so this test applies (art. 16(14)–(15)); and if you become resident again the following year, you are resident for the whole year (art. 16(16)). Income that Singapore does not tax at all — for example foreign-sourced income received by a resident individual, exempt under s. 13(7A) — cannot meet the 60% test. Singapore decides your status for the whole calendar year; where both countries treat you as resident for the same period, the Agreement decides.
IFICI («NHR 2.0»): 20% for qualifying newcomers. If you were not resident in Portugal in any of the previous five years and work in a qualifying activity (research and higher education, qualified jobs in companies with investment-incentive contracts, highly qualified professions in qualifying or exporting companies, R&D staff, certified start-ups, etc.), you may pay 20% on net employment and self-employment income from that activity for 10 years; most foreign income is exempt with progression (art. 81(4) CIRS). Register by 15 January of the year after you became resident — later registration works only from that year.
Non-habitual resident (NHR) regime: closed to new entrants. The NHR regime was repealed from 2024. It still applies for the rest of the 10-year period to people already registered and, under transitional rules, to those who became resident by the end of 2024 with qualifying pre-2024 documents. Registration matters: the Supreme Administrative Court has ruled that the NHR registration request is a condition of access to the regime, and that a late request works only from the year of registration.
Former Portuguese residents returning to Portugal (art. 12-A CIRS). If you were a Portuguese resident at some point, were not resident in the previous five years and become resident again by 2026, 50% of your employment and business income is excluded from IRS for 5 years (capped by reference to EUR 250,000 for people who became resident from 2024). «Resident» here means resident under art. 16 CIRS: a stay in Portugal for part of one of those years without meeting any art. 16 criterion does not rule out the regime (STA, uniformisation of case law, 29 April 2026). Taxpayers up to 35 may instead use IRS Jovem (art. 12-B), which cannot be combined with art. 12-A, NHR or IFICI.
Leaving Portugal: no general exit tax, except on crypto-assets. Portugal's IRS code has no general exit tax on shares or other assets of individuals who move abroad; the exception is crypto-assets that are not securities, where losing residence is treated as a disposal (art. 10(1)(k) and (25) CIRS; crypto held 365 days or more is excluded). Report the change of residence within 60 days and appoint a representative or join electronic notifications (art. 19 LGT). As a resident of Singapore — outside the EU/EEA — you need a tax representative in Portugal unless you join electronic notifications.
Certificates of residence and registration. To claim treaty benefits in Singapore as a Portuguese resident — for example the exemption of pay for short work in Singapore, or a reduced Singapore withholding rate — request a Portuguese tax residence certificate on the Portal das Finanças (issued online at once) and give it to IRAS with your claim, or to the Singapore payer. To claim them in Portugal as a resident of Singapore, apply to IRAS for a Certificate of Residence (online; processing takes 2–3 weeks). You need a Portuguese tax number (NIF) to deal with the Portuguese tax authority; keep your address up to date — a change is ineffective until reported, and a change of residence status must be reported within 60 days.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Agreement between the Republic of Singapore and the Portuguese Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, with Protocol, signed at Singapore in September 1999 (Portugal: Resolução da Assembleia da República n.º 85/2000, DR I-A n.º 288 of 15.12.2000), as amended by the Protocol of 28 May 2012 and modified by the MLI. The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

The treaty in detail: income, rates, the 183-day rule →

Terms you will come across in Portugal

residência fiscal: Portuguese tax residence under art. 16 CIRS
residência habitual: habitual residence — a home kept with a current intention to live in it makes you resident even without 183 days
IRS / CIRS: Portuguese personal income tax / the Personal Income Tax Code
IFICI («NHR 2.0»): 20% on qualifying employment and self-employment income of newcomers for 10 years
NIF: Portuguese tax number
Portal das Finanças: online portal of the Portuguese tax authority, where a tax residence certificate is issued at once

Questions

Can a home in Portugal make me resident without 183 days?

Yes, if you had it in conditions suggesting a current intention to keep and occupy it as your habitual residence. A holiday home, or a family home that you yourself only visit, does not.

Does Portugal tax my salary for a short assignment while I remain resident in Singapore?

Not if all three conditions of Art. 15(2) are met: not more than 183 days in Portugal in any twelve-month period commencing or ending in the calendar year, an employer not resident in Portugal, and pay not borne by a Portuguese permanent establishment or fixed base.

I leave Portugal for Singapore mid-year after 200 days there. Am I resident for the whole year?

Possibly. With more than 183 days in the year of departure you stay resident for the whole year unless you show that your later income is taxed in Singapore at a rate of at least 60% of the Portuguese rate (art. 16(14)–(15) CIRS); income Singapore exempts cannot meet that test.

Sources

Legislation and official guidance

art. 16(1)–(2) Código do IRS (CIRS) — You are a Portuguese resident for a year if in that year you (a) stayed in Portugal more than 183 days, consecutive or not, in any 12-month period beginning or ending in that year; (b) having stayed less, had in Portugal on any day of that period a dwelling in conditions suggesting a current intention to keep and occupy it as your habitual residence; (c) were on 31 December a crew member of a ship or aircraft serving an entity resident, or with its seat or effective management, in Portugal; or (d) performed public functions or missions abroad in the service of the Portuguese State (including as a Member of the European Parliament, art. 16(13)). A day of presence is any day, whole or partial, that includes an overnight stay in Portugal.
art. 16(3)–(5) CIRS (partial-year residence) — If you meet criterion (a) or (b), you are resident from the first day of your stay in Portugal — unless you were resident on any day of the previous year, in which case from 1 January. Residence ends on the last day of presence in Portugal, subject to art. 16(14) and (16). Residence is assessed separately for each member of a household.
art. 16(14)–(16) CIRS (year of departure) — You stay resident for the whole year of departure if you spent more than 183 days in Portugal that year and, after leaving, earn income that would have been taxable and not exempt had you remained resident — unless you show that the income is taxed, because of your residence, by a similar income tax in another EU/EEA State or, elsewhere, at a rate of at least 60% of the Portuguese rate. You are also resident for the whole year if you become resident again in the year after the one in which you lost residence.
art. 15 CIRS — Residents are taxed on all their income, including income obtained abroad; non-residents only on income obtained in Portugal. In a year of partial residence each status applies to its own period.
art. 18(1)(a), (h), (l) CIRS — Portuguese-source income includes employment income from work performed in Portugal or paid by an entity resident or with a permanent establishment in Portugal, income from and gains on Portuguese real estate, and pensions paid by Portuguese entities.
art. 71(1), (4), (17) CIRS — Final withholding: 25% on employment income, business and professional income and pensions obtained in Portugal by non-residents; 28% on most capital income paid by Portuguese entities; 35% where income is paid to accounts for unidentified third parties or involves listed low-tax jurisdictions.
art. 19(1), (3)–(8), (15) Lei Geral Tributária (LGT) — Your tax domicile is the place of your habitual residence; it must be communicated to the tax authority and a change is ineffective until communicated. A change of residence status must be reported within 60 days. Residents abroad (and residents absent for more than six months) must appoint a tax representative resident in Portugal — optional for EU/EEA cases, and not required if you join the electronic notification service (Morada Única Digital / Portal das Finanças notifications).
Art. 4(2) of the Portugal–Singapore Agreement (1999) — Dual-resident individual: (a) resident only of the State in which he has a permanent home available to him; with a permanent home in both States, of the State with which his personal and economic relations are closer (centre of vital interests); (b) if the centre of vital interests cannot be determined, or he has no permanent home available in either State, of the State in which he has an habitual abode; (c) habitual abode in both States or in neither — the State of which he is a national; (d) national of both States or of neither — the competent authorities settle the question by mutual agreement (Art. 26).
Annex A to the IRAS text — effects of the MLI (Portugal–Singapore) — The MLI replaces the preamble, Art. 9(2), supplements Art. 26(2), adds arbitration (Arts 26A–26H) and a principal purpose test (Art. 28A); Article 4 is not changed.
IRAS — List of DTAs, Limited DTAs and EOI Arrangements (updated 4 February 2026) — Singapore's comprehensive Avoidance of Double Taxation Agreements (DTAs), limited agreements covering only shipping and air transport income, and exchange-of-information arrangements; the texts of the agreements are published by IRAS.
s. 2(1) Income Tax Act 1947 (definition of «resident in Singapore», para (a)) — An individual is resident in Singapore if, in the year preceding the year of assessment, he or she resides in Singapore except for such temporary absences as may be reasonable and not inconsistent with a claim to be resident; also resident is a person who in that year was physically present or exercised employment in Singapore (other than as a company director) for 183 days or more.
Art. 15(2) of the Portugal–Singapore Agreement (1999) — Remuneration of a resident of one State for employment exercised in the other State is taxable only in the State of residence if (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the calendar year concerned, (b) it is paid by, or on behalf of, an employer who is not a resident of the other State, and (c) it is not borne by a permanent establishment or a fixed base which the employer has in the other State.
IRAS — «Working out my tax residency» (updated 12 May 2026) — A Singapore citizen or permanent resident who normally resides in Singapore, except for temporary absences, is a tax resident. A foreigner is resident for a year of assessment if, in the preceding calendar year, he or she stayed or worked in Singapore for at least 183 days, or stays or works in Singapore continuously for three consecutive years (then for all three years, even with fewer than 183 days in the first and third). A foreign employee whose employment spans two calendar years is resident for both years if the period of employment, together with the stay immediately before and after it, is a continuous period of at least 183 days (not for company directors, public entertainers and professionals). Days include weekends and public holidays, and temporary absences (leave abroad, business trips) connected with the employment in Singapore.
Art. 24 of the Portugal–Singapore Agreement (1999) — Portugal (para. 1): deduction from the tax on the income of a Portuguese resident of an amount equal to the income tax paid in Singapore on income that may be taxed in Singapore, not exceeding the part of the Portuguese tax attributable to that income. Singapore (para. 2): subject to its laws on credit for foreign tax, the Portuguese tax paid, directly or by deduction, is allowed as a credit against the Singapore tax payable on that income. Para. 3: income exempt in the State of residence may be taken into account in calculating tax on the remaining income.
Art. 23 of the Portugal–Singapore Agreement (1999) (limitation of relief) — Where the Agreement exempts Portuguese-source income or reduces Portuguese tax on it, and under Singapore law the income is taxed by reference to the amount remitted to or received in Singapore, the Portuguese exemption or reduction applies only to the amount remitted to or received in Singapore; not for the Government of Singapore and persons approved by both competent authorities.
s. 13(7A) ITA 1947 — Exempt is income from sources outside Singapore received in Singapore: (a) by a non-resident individual; (b) from 1 January 2004 — by a resident individual, where the Comptroller is satisfied that the exemption is beneficial to him or her; the exemption does not cover such income received through a partnership in Singapore.
IRAS — «Claiming foreign tax credit» — Where foreign income is taxable in Singapore and foreign tax has been paid on it, a resident can claim a foreign tax credit in the return; the credit is the lower of the foreign tax paid and the Singapore tax payable on that income.
art. 81(1)–(2), (4) CIRS — Foreign tax credit limited to the lower of the foreign income tax paid and the Portuguese tax on that income; under a tax treaty, not more than the tax the treaty allows the source State to levy. IFICI beneficiaries: foreign employment, business, capital, rental and capital-gains income is exempt but counts for the rate.
Art. 14(1) of the Portugal–Singapore Agreement (1999) — Income from professional services or other independent activities is taxable only in the State of residence, unless the individual has a fixed base regularly available to him in the other State (income attributable to it may be taxed there) or stays in the other State for a period or periods amounting to or exceeding in the aggregate 183 days within any twelve-month period (income from the activities performed there may be taxed there).
Arts 18 and 19 of the Portugal–Singapore Agreement (1999) — Pensions and similar remuneration paid to a resident of a State in consideration of past employment are taxable only in that State (Art. 18, subject to Art. 19(2)). Salaries paid by a State, its political or administrative subdivision, local authority or statutory body for services rendered to it are taxable only in that State, but only in the other State if the services are rendered there and the individual is a resident of that other State who is its national or did not become resident there solely to render the services (Art. 19(1)). Pensions paid by or out of funds of such a body for such services are taxable only in that State, but only in the other State if the individual is a resident and national of that other State (Art. 19(2)). Pay and pensions for services connected with a business carried on by such a body fall under Arts 15–18 (Art. 19(3)).
art. 58-A Estatuto dos Benefícios Fiscais (IFICI), added by Lei n.º 82/2023 — New residents who were not resident in Portugal in any of the previous five years and work in listed qualifying activities (higher education and research, qualified jobs in companies with contractual investment benefits, highly qualified professions in qualifying or exporting companies, R&D staff, certified start-ups, and others) may be taxed at 20% on net category A and B income from those activities for 10 consecutive years from the year of registration as resident. Not available to former NHR beneficiaries or ex-resident regime users; usable only once.
arts. 57(1), (6) and 60(1) CIRS; art. 143 CIRS — IRS is assessed on the calendar year (art. 143). The annual return (Modelo 3) for the previous year's income is filed electronically from 1 April to 30 June (art. 60(1)); if you had two residence statuses in the same year you file one return for each (art. 57(6)).
ITA 1947, s. 2(1) («resident in Singapore»), 62(4)–(5), 73(1); IRAS — «Working out my tax residency» (updated 12 May 2026) — Status is set for the whole calendar year and applies to the following Year of Assessment. A foreigner arriving is resident for that year with 183 days of presence or employment, or under the two-year or three-year administrative rules; a holder of a work pass valid for at least one year is provisionally treated as resident, and the status is reviewed at tax clearance. A person chargeable to tax notifies IRAS within one month of arrival.
Portaria n.º 352/2024/1 of 23 Dec 2024, art. 2(1) — The IFICI registration request must be filed by 15 January of the year after the one in which you became resident; a late request takes effect from the year of registration for the remainder of the period (art. 58-A(7) EBF).
art. 236(3)–(5) Lei n.º 82/2023 (State Budget 2024) — transitional NHR rules, reproduced under art. 16 CIRS — The NHR regime (former art. 16(8)–(12) CIRS) was repealed from 2024. It continues to apply for the remainder of the 10-year period to those already registered, to those who met the residence conditions by 31 Dec 2023, and to those who became resident by 31 Dec 2024 holding one of the listed pre-2024 documents (work contract, lease, school enrolment, residence visa, etc.) and who applied for NHR registration; a late registration takes effect only from the year in which it is made.
art. 12-A CIRS (regime for former residents) — 50% of employment and business income is excluded from tax for 5 years, within a cap set by the upper limit of the first bracket of art. 68-A CIRS (EUR 250,000; the cap applies to people who became resident from 2024), for people who become resident under art. 16(1)–(2) by 2026, were not resident in any of the previous five years but were resident at some earlier time, and have their tax affairs in order. Not combinable with NHR.
art. 12-B CIRS (IRS Jovem) — Taxpayers up to 35 who are not dependants may elect a partial exemption of category A and B income for 10 years of earning income: 100% in year 1, 75% in years 2–4, 50% in years 5–7, 25% in years 8–10, capped at 55 × IAS. Not available to NHR or IFICI beneficiaries or users of art. 12-A.
art. 10(1)(k) and (25) CIRS — For crypto-assets that are not securities, losing Portuguese residence is treated as a disposal for consideration (deemed sale on exit). Crypto-assets held for 365 days or more are excluded from the gains rules (art. 10(22)). No comparable exit charge on shares or other assets of individuals appears in art. 10.
Autoridade Tributária e Aduaneira (DSRI), note of 14 Dec 2021 on certification of tax residence — Since 1 Jan 2022 a Portuguese tax residence certificate for treaty purposes is requested online on the Portal das Finanças («Pedir Certidão» → «Residência Fiscal») and issued immediately; the AT says it is the only document attesting Portuguese residence for treaty benefits, and it is attached to the foreign form instead of having the form stamped.
IRAS — «Claiming exemptions under Avoidance of Double Taxation Agreements (DTAs)» (updated 27 October 2026) — A non-resident employee who is resident in a DTA partner state may claim exemption of employment income for short-term work in Singapore under the dependent personal services article if all its conditions are met; the claim is made to IRAS with a certificate of residence issued by the tax authority of the other state.
IRAS — «Claim of relief under the DTA» (withholding tax, updated 8 January 2026) — To apply a reduced treaty rate or an exemption, the Singapore payer obtains a certificate of residence of the non-resident payee from the other state's tax authority (in English or with an English translation, stating residence for treaty purposes and the years covered); non-resident professionals also sign Form IR586. The payer submits the certificate to IRAS by 31 March of the following year, otherwise the relief may be withdrawn.
IRAS — «Apply for Certificate of Residence» (updated 20 August 2026) — A Certificate of Residence (COR) for a state with which Singapore has a DTA is applied for through IRAS's online application; the form depends on the applicant's profile (Singapore citizen or PR employee, self-employed person, foreign employee with or without Singpass). Processing takes 2–3 weeks; the letter is available on myTax Portal if digital notices were chosen, otherwise it is mailed. A foreign tax authority's own form can be certified by IRAS on request (XLSX application and original form sent by post).
art. 68 CIRS (general rates) — Progressive IRS scale; the current text was last amended by Decreto-Lei n.º 212/2026 of 4 Nov 2026 (rates from 12.2% to 48%); a solidarity surcharge of 2.5% (EUR 80,000–250,000) and 5% (above EUR 250,000) applies on top (art. 68-A).
art. 72(1)(b)–(c), (2), (6) CIRS — Special flat rates: 28% on other income of non-residents not subject to withholding and on net gains on securities; 25% on residential rental income; 25% on income of non-residents attributable to a Portuguese permanent establishment and on their employment income and pensions not subject to withholding. Residents may opt to aggregate most of these items with their other income.
Art. 4(2)(a) of the Portugal–Singapore Agreement (1999) — A dual-resident individual is deemed to be a resident only of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, of the State with which his personal and economic relations are closer (centre of vital interests).
Art. 4(2)(b) of the Portugal–Singapore Agreement (1999) — If the State in which he has his centre of vital interests cannot be determined, or if he has no permanent home available to him in either State, he is deemed to be a resident only of the State in which he has an habitual abode.
Art. 4(2)(c), (d) of the Portugal–Singapore Agreement (1999) — If he has an habitual abode in both States or in neither of them, he is deemed to be a resident only of the State of which he is a national (c); if he is a national of both States or of neither of them, the competent authorities settle the question by mutual agreement (d; procedure in Art. 26).

Case law

Tribunal Central Administrativo Norte (TCAN), Tax Litigation Section, 01219/21.6BEPRT, 30/01/2025 — Tax domicile (art. 19 LGT) and tax residence for IRS are different concepts. A taxpayer who by mistake filed her 2019 return as a Portuguese resident could rebut her own return: Brazilian tax documents showed that she and her husband lived in Brazil, so the 183-day and dwelling criteria were not met and the assessment of her Brazilian income was annulled.
Tribunal Central Administrativo Sul (TCAS), Tax Litigation Section, 443/20.3BELRA, 27/11/2025 — Art. 16(1)(b) CIRS requires, besides a dwelling, a current intention to keep it as habitual residence — the place where a person normally lives and has the centre of family, social, professional and economic interests. A taxpayer who kept the same flat in Portugal and returned to it after each short absence abroad was resident; a foreign residence certificate issued later proved nothing about the earlier years, and the burden of proving non-residence was on the taxpayer.
Centro de Arbitragem Administrativa (CAAD), tax arbitration, 226/2023-T, 02/01/2024 — A football coach whose contract in China began on 1 August 2016, after 213 days in Portugal (no earlier departure was proven), stayed resident for all of 2016 under art. 16(14)–(15) CIRS because the Chinese tax on his later income was below 60% of the Portuguese tax. For 2017, owning a home in Portugal where his family lived did not make him resident without a current intention to occupy it as habitual residence (residence is assessed per person, art. 16(5)); the 2017 assessment was annulled.
Supremo Tribunal Administrativo (STA), Plenary of the Tax Litigation Section, 084/25.9BALSB (uniformisation of case law), 28/01/2026 — Filing the request for registration as a non-habitual resident under art. 16(10) CIRS (wording in force in 2023) is a condition of access to the NHR regime; meeting the substantive conditions is not enough without the request.
Supremo Tribunal Administrativo (STA), Tax Litigation Section, 0842/23.9BESNT, 29/05/2024 — NHR registration is declaratory, not a grant by the tax authority: if the conditions of art. 16(8) are met (assessed for the year of becoming resident), a request filed after the 31 March deadline is still possible, but the regime then applies only from the year of the NHR registration onwards.
Supremo Tribunal Administrativo (STA), Plenary of the Tax Litigation Section, 0214/25.0BALSB (uniformisation of case law), 29/04/2026 — For the former-resident regime (art. 12-A CIRS; here in the wording then in force, «three previous years» — now five), the condition of not having been resident refers to tax residence as defined in art. 16 CIRS. The tax authority may refuse the regime only if it shows that one of the art. 16 criteria was met in one of those years; it is not enough that the taxpayer stayed in Portugal for part of that year, for less than 183 days. The arbitral decision that had refused the regime was annulled.

Updated 10/11/2026. The result is for information only and is not tax or legal advice. IRAS, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law can change with each annual Budget. Consult a qualified adviser before making decisions.

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