Portugal cut its corporate income tax rate again this year. The general IRC rate is 19 percent for 2026, down from 20 percent, and the law already schedules further cuts to 18 percent in 2027 and 17 percent in 2028. That trajectory, approved in Law 64/2025 of 7 November 2025, is the good news, and it is real. The less visible news is that no Portuguese company pays exactly the headline rate. Surtaxes add to it, reduced rates subtract from it, and a uniquely Portuguese mechanism called autonomous taxation can quietly tax a loss-making company. This article walks through all of it with 2026 figures.
The headline rate: 19 percent, falling to 17
The general IRC rate applies to the worldwide profits of companies resident in mainland Portugal, and to the Portuguese profits of non-resident entities with a permanent establishment here. For tax periods beginning on or after 1 January 2026 the rate is 19 percent. The same law fixes 18 percent for 2027 and 17 percent for 2028, which matters for anyone modelling a multi-year business plan: profits you defer into later years are, on current law, taxed at a lower rate.
For context, this puts Portugal below the EU average headline rate and makes the often repeated claim that Portugal is a high-tax country for business increasingly out of date, at least at the corporate level.
The 15 percent SME rate on the first €50,000
Companies that qualify as micro, small or medium-sized enterprises, or as small mid-caps, pay a reduced rate of 15 percent on the first €50,000 of taxable income, with the general rate applying only to the excess. In 2025 this reduced rate was 16 percent, so the cut flowed through here too.
Most new companies formed by founders and investors qualify comfortably: the SME test looks at headcount and turnover or balance sheet totals, and a newly incorporated Lda is almost always inside the thresholds. On the first €50,000 of profit, the saving versus the general rate is up to €2,000 per year, every year.
The surtaxes: derrama municipal and derrama estadual
Two surtaxes sit on top of IRC, and this is where headline-rate comparisons with other countries go wrong.
Municipal surtax (derrama municipal)
Municipalities may charge up to 1.5 percent of taxable profit. The rate is set locally each year: some municipalities charge the full 1.5 percent, some charge less, and a number charge zero or exempt small companies to attract investment. Where your company has its registered office therefore has a small but real tax consequence.
State surtax (derrama estadual)
The state surtax only touches larger profits, in progressive bands:
| Taxable profit band | Rate |
|---|---|
| €1.5 million to €7.5 million | 3% |
| €7.5 million to €35 million | 5% |
| Above €35 million | 9% |
A company with profits below €1.5 million never sees the state surtax. At the very top, combining the 19 percent general rate, the maximum municipal surtax and the 9 percent top band, the marginal rate reaches 29.5 percent. For the small and mid-sized companies we typically incorporate, the realistic all-in range in 2026 is 15 to 20.5 percent.
Regional rates: Madeira, the Azores and the interior
The autonomous regions apply reduced IRC rates: in 2026 the standard regional rate is around 13 to 13.3 percent, with SMEs in the regions paying as little as 10.5 percent on the first €50,000. Companies established in inland low-density territories on the mainland can access a 12.5 percent rate on the first €50,000 of taxable income.
A caution from practice: these rates reward real presence. Registering a company in Madeira or a border municipality while the business is actually run from Lisbon or from abroad invites exactly the kind of substance questions no founder wants. The regional rates are excellent when the operation is genuinely there.
Autonomous taxation: the trap that taxes loss-making companies
This is the part of the Portuguese system that surprises foreign founders most. Autonomous taxation (tributação autónoma) is a separate tax on certain categories of expenses, charged regardless of whether the company made a profit. The main 2026 rates:
- Company cars (combustion): 8 percent of the annual vehicle costs for cars acquired below €37,500, 25 percent between €37,500 and €45,000, and 32 percent at €45,000 or above. The tax hits depreciation, leasing rents, fuel, insurance and maintenance, not just the purchase.
- Eligible plug-in hybrids: reduced rates of 2.5, 7.5 and 15 percent across the same price bands, extended in 2026 to vehicles meeting the Euro 6e-bis standard with official emissions of 50 to 80 gCO2/km.
- Fully electric vehicles: no autonomous taxation within the relevant acquisition limit, 10 percent above it.
- Entertainment and representation expenses: 10 percent.
- Undocumented expenses: 50 percent, on top of being non-deductible.
All of these rates increase by 10 percentage points in a year the company reports a tax loss. The 2026 budget softened this penalty: it does not apply if the company had taxable profit in one of the three preceding years and filed its returns on time, or if it is within its first three years of activity. Still, the practical advice writes itself: the expensive company car is one of the costliest ways to extract value from a Portuguese company, and the receipts folder is not optional.
The incentives that actually reduce the bill
Three regimes do heavy lifting for companies that plan ahead:
- ICE (incentive for company capitalisation). Companies that strengthen equity (cash capital increases, share premiums, retained profits moved to reserves) deduct a notional return on those amounts: the 12-month Euribor average plus a 2 percentage point spread, boosted by 20 percent in 2026. The deduction is capped at €4 million or 30 percent of EBITDA, with unused amounts carried forward five years. It rewards exactly what most founders should do anyway, which is capitalise the company properly instead of relying on shareholder loans.
- SIFIDE II. A tax credit for research and development spending, one of the more generous R&D regimes in Europe. Software and product development activity by tech companies frequently qualifies.
- RFAI. An investment support regime granting tax credits for productive investment in eligible regions, relevant for companies putting money into premises and equipment.
None of these applies automatically. They are claimed in the annual return, they have documentation requirements, and they are the reason the choice of accountant matters more than its monthly price tag suggests.
Tax losses: unlimited carryforward, with a cap
Tax losses generated in 2023 or later can be carried forward without time limit, but the deduction in any given year is capped at 65 percent of that year's taxable income, so a profitable year always produces some tax. Losses can be forfeited if 50 percent or more of the ownership changes hands, subject to exceptions, which is worth checking before any share sale in a company sitting on accumulated losses. There is no carryback.
What this means if you are forming a company now
Pulling the threads together for a founder incorporating a Portuguese Lda in 2026: your realistic tax rate on early profits is 15 percent up to €50,000 and 19 percent above it, plus up to 1.5 percent municipal surtax, with the general rate already legislated to fall to 17 percent by 2028. Capitalise the company properly and the ICE deduction reduces the bill further. Keep vehicles and undocumented spending under control and autonomous taxation stays a footnote instead of a line item.
Tax rarely decides whether Portugal is the right base, but it has stopped being an argument against it. The structure you choose at incorporation (share capital, equity versus shareholder loans, where the registered office sits) is what determines whether you capture the favourable parts of this system from year one.
Planning a Portuguese company in 2026?
We incorporate the company, handle the tax registrations and set the structure up so the 15 percent rate and the ICE deduction are available from day one. Incorporation from €1,500, every module priced upfront.
Book a consultationThis article is general information, not legal or tax advice. Rates and rules described are those in force for 2026 at the date of publication and can change. Speak with qualified Portuguese counsel about your specific situation before acting. Portugal & Co legal team.