Leaving France for Portugal: What Changes for Your Business (2026)
Audrey Marques
Consultant in business establishment & company formation in Portugal
Founder of Business Portugal, Audrey supports French-speaking entrepreneurs in setting up their company in Portugal and opening their bank account. She coordinates a network of partners (accountant, tax adviser) and points clients to the right contacts, she is neither an accountant, nor a tax adviser, nor a lawyer.
Leaving France for Portugal is not about changing a registered-office address: it is about moving the real centre of a life and an activity. As long as the move stays theoretical, nothing genuinely shifts, and the risk remains on the French side. When it becomes real, you live there, you run things there, you work there, the company enters a different tax and social world. This article reviews what changes concretely, and what to examine before you leave. It is informative and does not replace a tax adviser's analysis of your situation.
The trigger: actually moving, not just relocating a seat
The starting point is not setting up a Portuguese company, but the effective transfer of your residence and of the management of your activity. French tax residence is not simply “fewer than 183 days in France”: Article 4 B of the General Tax Code looks at the home or main place of stay, the place of the main professional activity and the centre of economic interests. Keeping any of these anchors in France means risking remaining taxable there, whatever your company's address.
The difference is clear between actually moving, you settle, you manage from Portugal, you have your substance there, and keeping your centre of life in France while registering a shell in Lisbon. The second case does not provide the security being sought: a Portuguese company run from France is in principle a place of effective management or a permanent establishment, and becomes taxable in France again. Substance prevails over the seat. Portugal only makes sense if you genuinely settle there.
What changes for the company: IRC, IVA, Segurança Social
Once the activity is genuinely carried by a Portuguese structure, an Unipessoal Lda for a single partner, a Lda from two partners, legal share capital of €1 per partner, the tax and social framework shifts to the Portuguese side. Profits fall under IRC, corporate income tax, at 19% on the mainland standard rate, with a reduced 15% rate for SMEs on the first €50,000 of profit. The NIPC, the company's tax number, is assigned at registration, and should not be confused with the individual's NIF, obtained beforehand.
On turnover taxes, you move from French VAT to Portuguese IVA, a 23% standard rate, with targeted reduced rates. For Portugal we say IVA, never “VAT”. The director who settles and works in Portugal registers with the Segurança Social, the Portuguese social-security system, whose contributions and rules differ from the French regime. These filing and accounting obligations are regulated: once the company is created, accounting is handled by a partner Contabilista Certificado.
And for the director: IRS and the IFICI question
Having become a Portuguese tax resident, the director falls under IRS, the Portuguese personal income tax, for their remuneration and other income. The trade-off between salary and dividends, which depends on your situation and on the France-Portugal treaty, signed on 14 January 1971, in force since 18 November 1972 and amended by the protocol of 25 August 2016, must be set with a professional, never on a ready-made scheme.
IFICI, which replaced the former Non-Habitual Residents regime (NHR), is regularly presented as the decisive argument. It must be framed: it is a targeted regime, reserved for qualified active profiles, which excludes retirees and requires prior recognition of the activity by the competent authority. It is never automatic, and many freelancers or e-commerce sellers are not eligible. IFICI can be a real asset for those who qualify, but it cannot be assumed: eligibility is assessed case by case with a tax adviser.
To anticipate before leaving: exit tax and the residual French risk
Some matters are handled before leaving, not after. Exit tax, set out in Article 167 bis of the General Tax Code, may concern unrealised capital gains on significant holdings at the time of transferring domicile out of France, with, under conditions, a deferral of payment for a move to the European Union or the European Economic Area. It is a point to map out beforehand with a tax adviser, because it shapes the timing and the real cost of leaving.
Beyond that, French law has anti-abuse mechanisms: Article 209 B targets certain controlled foreign companies, and Article 123 bis the individual holding at least 10% of a foreign entity with mainly financial assets subject to a privileged tax regime, within the meaning of Article 238 A. That privileged regime corresponds to taxation at least 40% lower than the French tax; yet ordinary Portuguese IRC is in principle not privileged, which remains to be assessed case by case. The overall logic is simple: for anyone who stays a resident of their country, the real risk lies in the country of residence, not in Portugal.
Building a move that holds
A solid transfer is prepared in order: securing residence and substance, choosing the right Portuguese structure, NIF then registration and NIPC, registering with the Segurança Social, setting up IRC and IVA, then examining the director's IRS and IFICI eligibility. Each block is documented, because it is the coherence of the whole that protects, not an address.
Since 2025, more than 75 entrepreneurs have been supported through this process. Business Portugal's role is to coordinate this sequence and connect you with the right partners, a Contabilista Certificado for accounting, a tax adviser for trade-offs, exit tax and IFICI. If you are considering taking the step, the right starting point is to examine your real situation before fixing anything.
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