Portugalの税務居住ルール：183日テスト
183日のしきい値
Portugalにおける183日ルールの仕組み
Portugal applies a 183 day calendar year test. Having a habitual residence also triggers it.
暦年（1月〜12月）. これは、日数カウントが毎年1月1日にリセットされることを意味します。前年の日数は繰り越されません。
183日を超えると、Portugalは税務居住者としてあなたの全世界所得に課税する可能性があります。具体的な影響は、個人の状況、適用される租税条約、所得の種類によって異なります。
日数のカウント方法
Portugal sets two main routes into tax residency. The first is the headline 183 days in a calendar year, consecutive or not. The second is having a dwelling available to you on 31 December under circumstances that suggest you intend to keep it as a habitual residence. Family ties to Portuguese residents can also weigh in as a residency factor on top of those two.
1日とみなされる条件
A day spent in Portugal for any part of it counts, including arrival and departure days. The 183 day threshold is a calendar year total rather than a continuous stay.
日数以外の判定基準
The habitual residence test can pull you into residency on its own. Keeping a Portuguese dwelling on 31 December that signals an intention to stay is enough, even if you spent fewer than 183 days in the country during the year. With under 183 days and no Portuguese home, the default is usually non resident.
特別税制
The Non-Habitual Resident (NHR) regime closed to new applicants in 2024. Its successor, sometimes called NHR 2.0 and formally IFICI, runs along similar lines for up to 10 years but only for qualifying tax residents from 2024 onward who work in specific scientific, technical, and other listed roles.
租税条約
Portugal has tax treaties with most major economies, including the US, UK, Canada, Brazil, and every EU member. The standard OECD tiebreaker applies in dual residence cases.
よくある質問
Is the NHR regime still available?
Not for new applicants. The original NHR closed at the end of 2023. A narrower successor regime (IFICI) launched for tax residents from 2024 onward and is restricted to people working in qualifying scientific, technical, and other specified roles.
Can I be resident in Portugal with fewer than 183 days?
Yes. If you keep a habitual residence in Portugal that suggests an intention to stay, you can be Portuguese tax resident on that basis alone. The 183 day rule is just one of the two main routes in.
How does Portugal treat Schengen 90/180?
Schengen 90/180 is a visa rule that sits entirely separately from tax residency. EU and Schengen citizens are not subject to it. Non EU travellers without a residence permit are capped at 90 days of total Schengen Area presence in any rolling 180 day window.
公式情報源: https://info.portaldasfinancas.gov.pt/