QROPS Advice: Taxation of ‘Non-Residents’ Living in Portugal

The basis for taxation in Portugal is determined by an individual’s residential status. Non-residents are liable to Portuguese tax on Portuguese source income, and non-residents receiving employment income from a Portuguese employer are subject to a
withholding tax of 20%.
Capital gains earned by non-residents are generally fully taxable at a flat rate of 25%, with an exception with respect to capital gains on the disposal of shares, which are taxed at 10%. Furthermore, if the shares are held for more than twelve months, the related capital gain will be exempt to taxation in Portugal as mentioned above. However, if the assets of the company to which the shares relate are composed of 50% or more of property located in Portugal the tax rate is 10%, regardless of the duration for which the assets are held.
Rental income earned by non-residents is taxed at a flat rate of 15% and there are no deductions available.
Non-residents who reside in a country with a low tax regime may be subject to higher rates of tax in respect of property transfers and may be subject to tax on deemed income from property.

full details on http://www.ailo.org/common/externalPage.asp?intURL=/publications/default.asp&extURL=/downloads/Portugal_2009.pdf