I agree, I would try Malta if going self employed.
Could you be more specific? 'Foreign' meaning from a Portugal perspective? You're saying company. Companies are subject to the corporate tax rate and then paying dividends (which is subject to witholding tax) to the NHR. The proposed solution...
So to sum it up: OP seems set on Portugal NHR programme. Since that is stricter than most non dom programs he needs to be the non-managing member in an Irish LLP. He needs to do this this year anyway since the NHR is getting cancelled. This time limit AND being a sole proprietor currently saves...
Thanks for that link! The exit tax you are mentioning is for companies according to your link:
'Exit taxation: to prevent companies from avoiding tax when re-locating assets.'
OP says he is self employed so he is free of this burden, isn't he ?
I thought it was an Irish LLP? Which would make it not a subject of Article 7(2) of ATAD as that is UK? What is your opinion?
Would you describe or link what law you are referring to, as I am not familiar with what 'PT law means'? Thanks!
You could open up shop in Ireland with a 12.5% corporate tax rate if that difference makes it worth it for you. You do need to have local management and control though.