DoubleTaxationSingapore – Portugal tax treaty: residence, 183 days, rates
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
- In force since: 16/03/2001
- Official text
If both countries treat you as resident
- 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)(a) of the Portugal–Singapore Agreement (1999)
- 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. Annex A to the IRAS text — effects of the MLI (Portugal–Singapore)
- 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)(b) 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). Art. 4(2)(c), (d) of the Portugal–Singapore Agreement (1999)
Income: who taxes it
| Income | Treaty rule | Article |
|---|---|---|
| Salary (employment) | The country where the work is done may tax it. Exempt if all apply: no more than 183 days in any 12-month period; the employer is not resident there; the pay is not borne by its permanent establishment there. | Art. 15(2) |
| Self-employment, business, services | Country of residence; the other country taxes profits of a permanent establishment (fixed base) there, or if your stay there reaches 183 days in any 12-month period. | Art. 7, Art. 14 |
| Pension | Only the country of residence. | Art. 18 |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1)-(2) |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1)-(2) |
| Rent from real estate | The country where the property is located may tax; the country of residence relieves double taxation. | Art. 6(1) |
| Dividends | Source country: at most 10%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 10(2) |
| Interest (deposits, bonds, loans) | Source country: at most 10%; the country of residence relieves double taxation. Other rates or exemptions apply in some cases (see the article). | Art. 11(2) |
| Royalties (copyright, licences) | Source country: at most 10%; the country of residence relieves double taxation. | Art. 12(2) |
| Sale of property or shares | Real estate: the country where it is located may tax. Other property, including shares: only the country of residence. | Art. 13 |
| Other income | The source country may tax; the country of residence relieves double taxation. | Art. 22(3) |
How double taxation is relieved
- Portugal: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 24(1)
- Singapore: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 24(2)
Data checked: 10/11/2026. A short summary for individuals; the full conditions, exceptions and protocols are in the treaty text. General information, not legal advice.