# Dutch expat tax in Portugal [Moving to Portugal](/moving-to-portugal/) Guide Updated 8 October 2026 Law as at 25 September 2026 4 min read Signed by our advisers · 4.7 on Google, 43 reviews Dutch private-sector pensions, annuities and AOW paid to Portuguese residents are taxable in Portugal, with Dutch tax also possible under treaty conditions. The Netherlands may also tax a private-sector pension or annuity under the treaty’s source-country pension exception, but only if it was built up with Dutch tax relief, Portugal taxes it below its general rate for employment income or taxes less than 90% of its gross amount, and the recipient's pensions, annuities and social security payments exceed EUR 10,000 gross in the calendar year. Dutch cases turn on three things: the conserverende aanslag (the Dutch exit charge) on the way out, how the treaty splits the AOW from occupational pensions, and whether any future treaty change alters pension taxing rights. Next step **Moving to Portugal, or already here with income from abroad?** Before the move, we assess your Portuguese tax position and work with your adviser abroad; once you live here, we prepare and file your Portuguese return. [Your annual return](/services/annual-portugal-tax-return-expats/) ## What changes when you move from the Netherlands to Portugal Leaving the Netherlands does not immediately end Dutch tax exposure. On top of that, the Dutch government aims to renegotiate the treaty so that the Netherlands can tax Dutch pensions at source, preferably in full (letter to parliament of 19 February 2025). No negotiating round has taken place since 2019, and Portugal remains on the Dutch negotiating list for 2026, so a move planned around Portugal-only pension taxation carries a forward risk. And on the Portuguese side, IFICI (the regime that replaced NHR) does not exempt [foreign pensions](/guides/portugal-pension-tax-guide/), so the old NHR benefit for Dutch retirees is gone. ## How the treaty between the Netherlands and Portugal allocates your income The Netherlands and Portugal tax under a double tax treaty, so each income type is allocated, with the other country giving relief. As a broad map: | Income type | Where it is taxed | Notes | | --- | --- | --- | | AOW state pension | Usually Portugal as residence country | Confirm the current treaty article and any Dutch domestic withholding position before filing. | | Dutch occupational or private pension | Possibly both | Portugal taxes as residence, but the Netherlands can tax at source where the treaty conditions are met (see below). | | Dutch government-service pension | Generally the Netherlands, except where the recipient is both resident in and a national of Portugal under the treaty exception. | | | Employment | Where the work is performed | Residence (Portugal) unless the work is physically done in the Netherlands. | | Dividends and interest | Netherlands may withhold, Portugal taxes with a credit | Reclaim Dutch withholding down to the treaty rate. | | Capital gains on securities | Portugal (residence) | Except the Dutch substantial-interest claim preserved by the conserverende aanslag. | | Dutch real estate (rent and gains) | Netherlands (where the property is) | Portugal taxes too and credits the Dutch tax. | ## The conserverende aanslag: the Dutch exit charge When you emigrate, the Belastingdienst can issue a conserverende aanslag, a protective assessment, over things built up while you were Dutch resident: most importantly a substantial shareholding (Box 2, for a DGA with a BV), treated as a deemed disposal at departure, and tax-facilitated pension and annuity rights. For a move to an EU country like Portugal, payment is automatically deferred without interest or a guarantee, so it is usually not an immediate cost. Two cautions: the substantial-interest protective assessment can remain in force without the former ten-year lapse. Deferral, reporting, and revocation consequences depend on the assessment date, transaction, and applicable conditions. ## Pensions: AOW versus occupational, and the treaty renegotiation The AOW state pension and an occupational or private Dutch pension can be taxed differently under the treaty. Occupational and private pensions built up with Dutch tax relief give the Netherlands a right to tax at source under the treaty’s source-country pension exception only if, in addition, Portugal taxes the pension below its general rate for employment income or taxes less than 90% of its gross amount, and the recipient's pensions, annuities and social security payments total more than EUR 10,000 gross in the calendar year. Under the treaty protocol, Portugal's general deduction for pension income does not on its own satisfy the condition on Portuguese taxation. Under IFICI, a Dutch pension that Portugal taxes is taxed at normal progressive Portuguese rates, not a reduced regime rate. The filing must follow the treaty actually in force for the year. ## Box 3 and Dutch assets after you leave For a non-resident, Box 3 is generally limited to specified Dutch property and related rights. The current system starts from a notional return but permits an actual-return counterproof; transition to a future actual-return system is not yet a universal completed change. ## Coordinating Belastingdienst and Finanças Keeping a Dutch company, Dutch property, or Dutch pensions usually means filing in the Netherlands and in Portugal at the same time. The work is making both filings rely on the same facts so the credits line up, the conserverende aanslag is tracked, and a possible treaty change is anticipated. ## Frequently asked questions ### Does the Netherlands still tax me after I move to Portugal? Generally only on Dutch-source income once you have emigrated and are treaty-resident in Portugal. ### What is the conserverende aanslag? It is a protective assessment the Netherlands issues when you emigrate, covering a substantial shareholding (for a DGA with a BV) and tax-facilitated pension or annuity rights. The substantial-interest assessment now lasts indefinitely and can be triggered by selling the shares or by failing to file the annual statement. ### Is my AOW taxed in Portugal or the Netherlands? In practice the AOW state pension is taxable in Portugal as your country of residence; Dutch case law has held the Netherlands may not tax a Portuguese resident's AOW. An occupational or company pension can be different and may be taxable in the Netherlands at source. ### Does IFICI cover my Dutch pension? No. IFICI, the regime that replaced NHR, does not exempt foreign pensions. Most retirees do not qualify for IFICI. ### Is the Netherlands-Portugal treaty changing? The Dutch government’s letter to parliament of 23 April 2026 lists Portugal among its ongoing treaty negotiations: the Netherlands aims to agree source-state taxation of pensions, preferably in full, but the negotiations have not resumed since the first round in 2019. The government’s quarterly treaty overview, in its 1 July 2026 edition, lists the 1999 convention as in force. A negotiation announcement does not change the rule for a pension payment. This guide is by **[Telmo Ramos](/about/)**, our founder, an economist and member no. 16379 of the Ordem dos Economistas. ## Related guides - Guide · Law as at 19 October 2026 ### [How Portugal taxes foreign pensions in 2026](/guides/portugal-pension-tax-guide/) Portugal taxes a resident's foreign pension as Category H income at the progressive IRS rates, after the standard specific deduction of EUR 4,587.09 per recipient in 2026. - Guide · Law as at 19 October 2026 ### [Foreign income in Portugal: Anexo J step by step](/guides/portugal-foreign-income-tax/) A Portuguese tax resident is taxed on worldwide income, including income obtained abroad. - Guide · Law as at 13 June 2026 ### [Moving to Portugal: tax checklist for 2026](/guides/moving-to-portugal-tax-checklist/) Plan the tax steps before and after a move to Portugal: home-country departure, tax residence, NIF, income records, IFICI and your first return. ## Tell us about your situation For people living in Portugal with ties to the Netherlands: we answer your questions, prepare your Portuguese return with your income from the Netherlands and work with your adviser there. We reply within 2 working days with the right service, its price and how to start. ## Tax Consultation A 30-minute call with your adviser, then a follow-up memo within 3 working days after the call. [Book a Tax Consultation](/book/) --- Source: https://taxbordr.com/guides/dutch-expat-tax-portugal/ General guidance only. Individual facts govern.