As of January 2026, the new Double Tax Treaty (DTT) between Portugal and the UK is officially in effect. This marks a major milestone in cross-border taxation, introducing modernised rules that align with international standards.
Key highlights include:
- The removal of Article 14 and the extension of income definitions for immovable property.
- New clauses in Article 20 and updated capital gains provisions to specifically address income distributed from trusts.
- New rules for directors' fees and specific regimes for sportspersons and artists.
- A more robust definition of Permanent Establishment (PE) to prevent tax base erosion.
The MFA Legal & Tech team is available for any further clarification on this matter.
