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Wow your questions are the exact same as I have.  I am looking at meeting with an accountant and attorney to get answers.  I want to live both places. I actually have German citizenship which makes residency a lot easier for me but worry about taxes and we are in 70s and would need to get private heath care as far as I have found AND MGEN IS THE ONLY ONE.

My understanding from the US (and I hope JohnnyPT will correct me if I have misunderstood) is that the Portuguese tax is 45% less the 30% tax you paid in the USA due to an agreement they have to not do double taxation on income. I also understand that Portugal has a progressive tax where the entire income is not taxed at that rate, but I have no idea how that works if the first 30% goes to the US government. We were thinking about March, now January, and maybe even sooner if we can figure something out... It's complicated when I'm still working full-time, but it's harder and harder to do my job in a country that no longer respects my profession (doctor).

Some notes on taxable income and tax rates:

1. If you live 183 days/year, you become a tax resident in Portugal. This means that you have to declare all your income earned that year, including all the taxes you paid on that income.

2. There is an agreement between the US and PT to avoid double taxation on the same income. In other words, income taxed in the US is not taxed in PT, but you have to declare in PT these taxes paid in the US.

3. The application of tax in PT on income that has not been subject to tax in the US is done as follows:

Example:

You have an income of x, which has not been subject to tax in the US.

You withdraw 4,462.15 euros from this amount x, giving you the amount y.

(4,462.15 eur is an amount on which nobody pays tax in Portugal).

After the specific deduction that applies to all taxpayers (in 2025 this amount is 4,462.15 eur), you have obtained a taxable income y = 18,000 eur. To calculate the tax rates, you need to realise which bracket fits entirely within your taxable income. In this case, it's the third bracket, which goes from 12,160 eur to 17,233 eur.

Taxable income: y = 18,000€

IRS brackets:

3rd bracket: €12,160 and €17,233

Average rate: 16.482%

Standard rate for the next bracket (4th bracket): 22%

Step-by-step calculation:

1st part of the income (up to the limit of the 3rd bracket):

17.233€ × 16,482% = 2.841,22€

2nd part of the income (surplus that enters the 4th bracket):

18.000€ - 17.233€ = 767€

767€ × 22% = 168,74€

Total tax payable in PT:

2.841,22€ + 168,74€ = 3.009,96€

It's complicated when I'm still working full-time, but it's harder and harder to do my job in a country that no longer respects my profession (doctor). - @gwalks

Hi @gwalks,

You can apply for non-habitual resident (NHR) status because your profession has a high added value.  In this case you pay in PT a flat rate of 10% of the y amount (please read my previous post).

@JohnnyPT

Does the NHR work even if I'm not working in Portugal?

Although I'll miss seeing patients and would like to work part-time, even if I volunteer, but I haven't looked into whether my medical license would be accepted or what opportunities might exist that wouldn't interfere with periodic travel.

@gwalks

NHR for pensioners ended at the beginning of 2024. The income tax rates for foreign pensioners are the same as for Portuguese citizens.

@JohnnyPT  I've heard that the mínimo de existência has been increased to €12,180 annually for 2025 which will mean anyone in receipt of only the UK State Pension will pay no/little income tax. Could it be true?

@JohnnyPT I've heard that the mínimo de existência has been increased to €12,180 annually for 2025 which will mean anyone in receipt of only the UK State Pension will pay no/little income tax. Could it be true? - @northernlites

@northernlites,

These are the minimum resources for 2025:

/forum/viewtopic.p … =2#5973389

But as the link says, these amounts are not enough to live on, and I doubt that AIMA will authorise your residence if you only have these minimum income amounts.

As for taxes, the income brackets for 2025 are as follows:

@JohnnyPT Thanks. That's not exactly what my point was but presumably if anyone has demonstrated sufficient income to have the D7 approved, AIMA are not going to decide something else, surely!?

@northernlites,

If you have no other passive income, and your pension is equivalent to the minimum required by AIMA, then I suggest you to apply. The worst that can happen is that you get refused. If you are approved, the tax payable on your annual income (if you have not been taxed in your country of origin and have no other income) will be minimal indeed (equal to or close to zero).