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UK-Portugal Tax Treaty: 2025 Convention and 2026 Rules

The UK-Portugal tax treaty entered into force on 29 December 2025, but its UK Income Tax and Capital Gains Tax rules take effect on 6 April 2026. A UK Income Tax event before that date still falls under the 1968 convention.

Vineyard terraces above the Douro river near Pinhão

Common questions

Which UK-Portugal treaty applies from 2026?
The convention signed in London on 15 September 2025, in force since 29 December 2025. Article 28 keeps the 1968 convention in effect for income arising before the 2025 convention takes effect for the tax concerned.
When does the new convention apply in the UK?
From 1 January 2026 for taxes withheld at source, 6 April 2026 for Income Tax and Capital Gains Tax and 1 April 2026 for Corporation Tax, under Article 28. Portugal applies it from 1 January 2026 for taxes withheld at source and other taxes, and Article 28 keeps the 1968 convention in effect for income arising before those dates.
What is the Article 10 dividend cap?
Article 10(2)(a) caps source-state tax at 10% of the gross amount of a beneficially owned dividend, and Article 10(2)(b) sets 15% for the investment-vehicle property-income case. The recipient, payer and article conditions apply before a repayment claim.
How does Portugal credit UK tax?
Article 21 makes Portugal deduct the tax paid in the UK on the income or capital gains from the Portuguese tax on that resident's income, and CIRS Article 81 limits the deduction to the Portuguese tax attributable to the same income. A UK Capital Gains Tax charge therefore counts in the same way as UK Income Tax.
When can arbitration apply?
Only when an Article 23 mutual-agreement case stays unresolved for three years and the dispute falls under Article 5, 7 or 9, the list in Protocol Part IX. Protocol paragraph 2 alone provides the arbitration; paragraph 1 defines the comparable interest used in Article 13(2).
Which taxes does the UK convention cover?
Article 2 lists Portuguese IRS, IRC and the relevant capital-gains taxation on one side and the UK's Income Tax, Corporation Tax and Capital Gains Tax on the other. Social contributions and any charge outside Article 2 are tested separately.

The information on this page is checked against official sources and reviewed regularly. It is corrected when the law or official guidance changes, as the Editorial Standards describe.