Frequently asked

The questions I get asked most.

Live questions, taken from the threads people search for on Reddit, X, and Portuguese tax forums. Grouped by topic; updated for 2026.

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Topic 01

Working with me.

The questions a future client tends to ask before booking a discovery call. Scope, format, pricing, confidentiality, fit.

Who do you typically work with?

Founders, crypto investors, and individuals navigating cross-border tax decisions. My deepest work sits in three areas: Portuguese crypto taxation, international tax structuring, and pre-move planning for relocations to or from Portugal. If your situation sits clearly outside those, I will say so on the discovery call and point you to someone better suited to your area.

How does the discovery call work?

Fifteen minutes, free, booked on Cal.com. You describe your situation in broad strokes. I confirm whether we are a fit, what shape the work would take, and what comes next. No commitment from you. If we move forward, you receive a written proposal within 48 hours with fixed scope, fixed price, and a working timeline.

Do you handle the actual tax filing or only the advisory?

I am a tax advisor, not a certified accountant. The strategic and structural work is mine: the diagnosis, the written plan, the structuring memo, the filing strategy. The actual submission of the Modelo 3 or the bookkeeping of a company is typically done by a contabilista certificado (CC). For clients who do not already have one, I refer to a small network I trust. The two functions work side by side: I design, the CC files.

How much does it cost to work with you?

The discovery call is free. Standalone consultations are €110 for one hour and €200 for two hours. Scoped engagements (compliance, relocation, structuring, advisory partnership) are quoted in writing after the discovery call. Every situation is different, so I quote per case rather than publish package prices. The full rate card sits on the pricing page.

In which languages and formats do you work?

Portuguese, English, and Spanish. All engagements are remote by default: discovery and review calls happen on video, written deliverables arrive by email or secure document sharing. In-person meetings are possible in the greater Lisbon area on request, but remote is the standard.

Is what I share with you confidential?

Yes. All client communications, documents, and case details are treated as confidential under standard professional confidentiality. Every engagement includes a written agreement covering scope, confidentiality, and intellectual property. Client details, screenshots, or names are never shared externally without explicit written consent.

Do you offer one-off engagements or ongoing advisory?

Both. One-off engagements have a fixed scope, fixed price, and a clear delivery point: a written plan or memo, plus a review call. The Advisory Partnership is an ongoing retainer with quarterly strategy reviews, unlimited email questions with a 48-hour response window, and annual filing coordination. The right format usually becomes clear during the discovery call.

What if my case is outside what you do?

I say so on the discovery call and, where possible, point you to a specialist who handles your area better. The brand is built on honesty about fit. Taking on cases outside my core expertise does not serve you and does not serve me. If we both decide it is not a fit, the call ends there with no obligation either way.

Topic 02

Crypto and the 365-day rule.

Swap mechanics, the holding-period clock, and the PIV 28969 carve-out. Grounded in Article 10 of the IRS Code.

If I swap BTC for ETH, do I lose the 365 days I already had?

Yes. The swap itself is not taxed (Article 10(20) CIRS), but the new asset starts a new holding period. Your 365-day count restarts at the date of the swap. The only carve-out is the narrow technical-conversion exception in PIV 28969, for stablecoin swaps done immediately before a fiat sale where no direct EUR pair existed.

Does swapping BTC for USDC and then selling for euros reset the clock?

Not if it qualifies as a technical conversion under PIV 28969. The PTA accepts that, when BTC is swapped to USDC only to enable the euro off-ramp and that off-ramp is immediate, the original holding period survives. Same trading session is the safe pattern; days or weeks holding the stablecoin breaks it.

If I rotate between stablecoins (USDT to USDC), do I also lose the holding period?

Most likely yes. PIV 28969 covers the stablecoin step as an immediate stop on the way to euros, not strategic rotation between stablecoins (yield, issuer risk, chain). Without immediacy and without the euro sale at the end, the prudent reading is that the new stablecoin starts a fresh 365-day clock.

Does a crypto-for-crypto swap pay tax at the moment of the swap?

No. Article 10(20) CIRS defers taxation until the consideration is no longer a crypto-asset. The taxable moment is the sale to euros or the payment for goods or services with crypto. The original acquisition cost rolls into the new asset.

If my counterparty is on a non-EU exchange (Binance, Kraken), does the 365-day exemption still apply?

Article 10(21) CIRS removes the swap-neutrality (and the 365-day exclusion that depends on it) when the counterpart is not resident in another EU or EEA Member State or in a jurisdiction with a tax treaty or information-exchange agreement with Portugal. Most major exchanges (including EU-licensed branches of Binance and Kraken) sit inside that perimeter. The test is the counterpart entity, not the brand. Check the specific entity in the terms of service.

Do I have to report a crypto-to-crypto swap even if no tax is due?

Today, the Modelo 3 does not have a specific field for crypto-to-crypto swaps. Disposals to euros go on Anexo G or Anexo G1 depending on the holding period. Best practice: keep an internal ledger of every swap (date, assets, EUR value at the time, fees). That ledger is what proves your acquisition cost and your 365-day clock when the next euro sale lands. From 1 January 2026 DAC8 makes reporting automatic anyway.

If I sell BTC at 11 months and rebuy immediately, do I count 365 days from zero again?

Yes. The sale to euros is the taxable event; the gain enters Anexo G at the 28% flat rate because the holding period was under 365 days. The rebuy starts a new holding period from the new acquisition date. Portugal does not have a wash-sale rule, but you have just paid 28% on a gain that was a month away from being tax-free.

Topic 03

Declaring crypto on Portuguese IRS.

Which Anexo applies, which rate, what changed in 2026. The questions that flood Portuguese tax forums every spring.

I have held crypto for over a year and haven't sold. Do I have to declare it on IRS?

No. Mere holding does not trigger a tax event. The obligation arises with a disposal to euros, payment with crypto, or receipt of passive income (staking, airdrops, lending). Foreign-platform balances in EUR may still be reported in Anexo J, quadro 11, when applicable.

What is the difference between Anexo G and Anexo G1 for crypto?

Anexo G, quadro 18A: taxable disposals, crypto held under 365 days sold to euros or used in payment. 28% flat (or aggregate). Anexo G1, quadro 7: excluded disposals, crypto held 365 days or more, or other exclusions. Reporting on G1 is mandatory even when no tax is due, because that quadro is where you prove the holding period.

Are my staking rewards Category E or Category B?

It depends on form and habituality. Rewards from delegated staking, liquid staking (Lido, Rocket Pool), or single validators inside a pool: Category E, Anexo E, 28% flat, valued at fair market value on the day. Rewards from running a validator as an organised business, providing staking services to third parties, or staking exercised as a regular professional activity: Category B, Anexo B, simplified regime usually applies a coefficient of 0.15.

I traded on Binance or Kraken all year. Does it go on Anexo G or Anexo J?

Disposals through a platform headquartered outside Portugal go on Anexo J (foreign-source income), quadro 9.4 (crypto gains at 28% flat), not on Anexo G. Exempt long-term holdings can be reported in dedicated fields of Anexo J. Fiat balances kept in the platform are reported as a foreign financial institution account (Anexo J, quadro 11). From 1 January 2026 DAC8 makes the platforms themselves report automatically.

When am I considered a professional trader? How many trades per year?

There is no fixed number. Article 3 CIRS defines Category B income (business or professional activity) by habituality, organisation and profit intent, not by a transaction threshold. Indicators used by the AT: daily or intraday frequency, dedicated infrastructure (terminals, bots), volume material relative to total wealth, economic dependence on the trading income, registered business activity. Frequent trading on top of a salary, even if active, does not automatically convert the activity into Category B; trading as the main source of income, usually does. The analysis is case-by-case.

I didn't declare crypto in previous years. How do I regularize now?

Through a substitution Modelo 3 declaration for the missing years, with the relevant annexes (G, G1, E, B or J) and payment of tax due plus compensatory interest. If you regularise before any audit or AT notification, Article 29 RGIT allows a waiver of the fine for the first infraction in the last 5 years. Even after notification, Article 30 RGIT reduces the fine to 12.5% of the legal minimum. Once DAC8 reporting starts (2026 transactions reported by 31 May 2027), the window for spontaneous regularization shrinks dramatically.

If I did 200 crypto-to-crypto swaps in 2025, do I have to list each one on IRS?

Not in the disposals field, because crypto-to-crypto swaps are not a taxable event under Article 10(20) CIRS. You only declare disposals to euros (Anexo G or G1) and passive income (Anexo E or B). But keep a complete internal record of every swap, with date, assets, quantities, EUR value, and fees. That record is what calculates your acquisition cost and starts the 365-day clock for assets you later sell to euros. DAC8 will report this via the platforms from 2026.

I received a free airdrop. How do I declare it?

Airdrops are treated as Category E capital income (Anexo E) or Category B business income (Anexo B) where received in the context of a regular activity. The EUR market value at the date of receipt is taxed at 28% (Anexo E) or under the applicable Category B regime. That value also becomes the acquisition cost of the token for future capital gain purposes, and the 365-day clock of Article 10(19) CIRS starts at the date of receipt. Airdrops with no determinable market value on receipt can be taxed only at the moment of sale.

Topic 04

Tax havens and the 5-year shadow.

Moving to Dubai, the UAE residency visa, the proof clause that breaks the deemed-residence presumption. Article 16(6) CIRS and the case law that interprets it.

I have an Emirates ID and live in Dubai. Am I still a Portuguese tax resident?

An Emirates ID and a UAE residency visa do not, on their own, take you out of Portuguese tax residence. Article 16(1) CIRS applies based on 183-day presence and habitual home tests. Article 16(6) CIRS adds the special rule: Portuguese nationals who move tax residence to a blacklisted jurisdiction (the UAE is on the list) are presumed Portuguese tax residents for the year of the move and four subsequent years, unless they prove the move is driven by valid reasons. Update your tax domicile on the Portal das Finanças, get a UAE tax-residency certificate, and document the substance of your life in the UAE.

Does the 5-year rule of Article 16(6) apply if I don't have Portuguese nationality?

No. Article 16(6) CIRS applies specifically to persons of Portuguese nationality who transfer residence to a country, territory or region on the Portaria 150/2004 list. Foreign nationals are subject to the general residence rules (183 days, habitual home) and the standard exit regime, without the extended 5-year presumption. Dual nationality counts as Portuguese nationality for this rule.

Is Dubai still on Portugal's blacklist in 2026?

Yes. Portaria 292/2025, in force from 1 January 2026, removed Hong Kong, Liechtenstein and Uruguay, but kept the United Arab Emirates on the list annexed to Portaria 150/2004. Article 16(6) CIRS therefore continues to apply to Portuguese nationals moving to Dubai, Abu Dhabi or any other emirate, with the presumption of Portuguese tax residence for 5 years.

If my family stays in Portugal and I go alone to Dubai, am I still tax resident here?

Likely yes. Article 16(2) CIRS extends Portuguese tax residence to anyone who, on the last day of the year, is part of a household where the spouse or partner is a Portuguese resident. This presumption can be rebutted with proof that your centre of vital interests (permanent home, economic and personal ties) is in the UAE. CAAD case law accepts broad evidence, but the presumption is strong and requires consistent documentation.

How do I break the 5-year presumption? What proof does the AT accept?

The escape clause sits inside Article 16(6) itself and allows the taxpayer to prove that the move is driven by valid reasons, such as temporary work for a Portuguese-domiciled employer abroad. CAAD jurisprudence goes further and accepts: a local employment contract, a tax-residency certificate from the UAE authority (referring to the UAE-Portugal treaty), permanent housing records, school enrolment for children, primary bank account, insurance, association ties. No statutory checklist exists; the test is convergence of indicia.

If I sell crypto while living in Dubai, do I have to declare it in Portugal?

It depends on your residency status that year. If you are deemed a Portuguese tax resident under the Article 16(6) 5-year shadow, the income is taxed in Portugal on a worldwide basis, even if the sale happens in Dubai and the euros never enter a Portuguese account. Standard Portuguese crypto rules apply, but where you trade matters: the 365-day exemption of Article 10(19) survives if you use a compliant EU/EEA exchange. Article 10(21) CIRS removes the exemption only when the counterpart or exchange entity is domiciled in a blacklisted jurisdiction. If you trade via a haven-based exchange, the AT reads Article 72 to apply the aggravated 35% rate regardless of the holding period. If you are non-resident, crypto sales generally fall outside Portuguese tax, but the burden of proving non-residence is on you.

What if I go to Switzerland, Monaco or Cayman instead of Dubai? Is there a difference?

Yes. The 5-year rule of Article 16(6) CIRS only applies to jurisdictions on Portaria 150/2004. Switzerland is not on the list. Monaco remains on the list. Cayman Islands remain on the list. The 365-day rule of Article 10(19) CIRS additionally requires that the counterpart is not domiciled in a listed jurisdiction (Article 10(21) CIRS). Moving to Switzerland avoids the Article 16(6) problem but still requires confirming residence under the general rules; moving to Monaco or Cayman keeps both problems alive.

Topic 05

Ecommerce VAT and IOSS.

How non-EU sellers ship into Portugal under the current EU import rules, the IOSS regime and intermediary, and what changes from 1 July 2026.

Do I need a separate VAT registration for each EU country I sell to?

No. IOSS is a single registration that covers all 27 Member States for B2C imports up to 150 EUR. You register in one Member State (the Member State of identification, normally your intermediary's home country) and file one monthly return there, in euros.

Can I sell into Portugal without IOSS?

Yes. The buyer (or the courier on the buyer's behalf) pays the import VAT at delivery, plus a handling fee. The buyer experience is poor: surprise charge at the door, sometimes refusal. For a serious ecommerce operation shipping more than a handful of parcels a month into the EU, IOSS pays for itself in conversion rate and reduced returns within weeks.

Should I use IOSS or DDP for parcels just under 150 EUR?

IOSS is structurally cheaper above ~20 parcels a month, because the per-parcel cost approaches zero as volume scales. DDP is per-parcel: the courier collects a handling fee on every single shipment. Run the maths on your monthly volume; the break-even is usually around 15 to 30 parcels for European destinations.

What changes for the buyer experience on 1 July 2026?

A €3 flat customs duty is added per product category (6-digit HS sub-heading) inside low-value parcels (intrinsic value below 150 EUR). The duty stacks: a parcel containing different types of items pays €3 per HS6 category. It is paid at the border, not at checkout under current rules. For a smooth experience, factor the duty into your shipping price and disclose it in the cart, even if IOSS continues to handle the VAT side at checkout.

Do I need to issue a Portuguese invoice for an IOSS sale?

No. Under IOSS the seller issues an invoice in line with the rules of the Member State of identification, not Portugal. The Portuguese e-fatura system does not apply to non-EU sellers shipping into Portugal through IOSS. Keep the invoice in English or your home language, with the IOSS number, the VAT charged, and the buyer's full address.

Your question is not here?

Every case is different. If yours does not fit the patterns above, book a discovery call and we look at it together.

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