Italy – Portugal Tax Treaty
The Italy-Portugal tax treaty caps withholding on dividends at 15% for portfolio investors and 5% for qualifying direct investment, and interest at 15%. Royalties are taxed at a uniform 12% across all categories. Private pensions are taxable only in the country of residence, with no withholding at source. This is one of 47 active treaties in Italy's network and one of 28 in Portugal's. The general dividend rate of 15% compares to a median of 15% across Italy's network and 15% across Portugal's.
Verified data
AT Portugal International Tax Treaties (portaldasfinancas.gov.pt) (Treaty list verified April 2026. Rates from individual treaty texts (Articles 10-12).)
Withholding Rate Summary
Source: Portugal Treaty Reference| Income Type | Treaty Rate | Statutory Rate (Portugal) |
|---|---|---|
| Dividends (general) Portfolio investors | 15%saves 10% | 25% |
| Dividends (qualified) Beneficial owner is a company holding >= 10% of voting stock | 5%saves 20% | 25% |
| Interest Bank interest, bonds, loans | 15%saves 10% | 25% |
| Royalties (avg) Patents, copyright, know-how, film/TV | 12% | — |
| Pensions Private pension distributions | 0% | — |
| Social Security Government social security benefits | 0% | — |
“Treaty Rate” is the maximum withholding permitted under this treaty. The actual effective rate may be lower if domestic law provides a more favorable rate independently. “Statutory Rate (Portugal)” shows the rate that applies when no treaty benefit is claimed. Qualified dividend rate requires: Beneficial owner is a company holding >= 10% of voting stock.
Dividends
The general dividend rate of 15% applies to portfolio investors. A reduced rate of 5% is available when beneficial owner is a company holding >= 10% of voting stock. Without the treaty, the statutory withholding rate on dividends is 25%.
Source: Portugal Treaty Reference
Interest
Interest payments (bank interest, bonds, loans) are subject to 15% withholding under this treaty, compared to the 25% statutory rate. This represents a 10% reduction from the statutory rate.
Source: Portugal Treaty Reference
Royalties
Royalty withholding rates vary by the type of intellectual property. This treaty distinguishes 4 categories, with rates ranging from 12% to 12%.
Source: Portugal Treaty Reference
Pensions & Social Security
Private pension distributions are taxable only in the country of residence, with no withholding at source. Government social security benefits are exempt from source-country withholding.
Source: Portugal Treaty Reference
Comparative Context
🇮🇹Italy's Network
Among Italy's 47 active treaty partners, the 15% general dividend rate ranks 39th (median: 15%).
| Partner | Rate |
|---|---|
| New Zealand | 15% |
| Philippines | 15% |
| Pakistan | 15% |
| Portugal (this treaty) | 15% |
| Sweden | 15% |
| Singapore | 15% |
| Slovak Republic | 15% |
🇵🇹Portugal's Network
Among Portugal's 28 active treaty partners, the 15% general dividend rate ranks 22th (median: 15%).
| Partner | Rate |
|---|---|
| Ireland | 15% |
| Israel | 15% |
| India | 15% |
| Italy (this treaty) | 15% |
| South Korea | 15% |
| Norway | 15% |
| Poland | 15% |