Portuguese resident NHR: Best company location/structure

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G1 category : More than 365‍ days holding (tax free)
G category : Less than 365 days holding = 28% tax.⁠
 
Hey, what about:

1. Property rent from abroad of Portugal under NHR regime - you‌ still pay 0%? Do one need to show to Portugal authorities that they have payed‍ their taxes abroad for those properties? And what about income from renting properties in Thailand⁠ which don't have tax treaty with Portugal, will they tax you 28% on that?

2. If one have NHR, living in Portugal and wants to start providing consulting services online⁤ - should he/she opened Portugal company and will this income be taxed at 28%?
 
Yes, but what structures do they have? SMLLC or MMLLC? Because in the⁠ second one there seems to have been a ruling that manages to make the Portuguese⁤ tax authorities “accept” the situation. But for the first one it's not clear, do you⁣ know anything more?
 
Did you read the‍ ruling?

The second partner was tax resident in US and paying taxes.

It's very clear, you are generating a⁠ PE in Portugal by managing US LLC from there.

The question you have to ask⁤ is: "Am I ok running the risk of potentially getting caught?"
 
Clear. What % do you think is the‍ risk, indicatively? (Are you an international tax lawyer? Or a similar expert?) Do you know⁠ people who have been doing this for years? But then, if they ever find someone⁤ in such a situation, what do they risk?

Sure. I read that. In fact I said AT accepts it because⁢ it is a multi member LLC (with US resident).
 
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