Malta vs Portugal for your company and tax base.

Portugal raised the stakes: NHR is closed to new applicants, the IFICI replacement is narrow, and mainland IRC still stacks surcharges on top of 19%. Malta answers with ~5% effective corporate tax under general law and a remittance-basis personal regime. Here is the honest side-by-side.

If your revenue is Portuguese customers served locally, a Portuguese company is usually the right answer and we will tell you so. Malta earns its keep when income is international: cross-border services, IP and royalties, holdings, e-commerce and mobile founders - profiles where the refund system, participation exemption and treaty network compound.

Corporate tax. Portugal: 19% IRC in 2026 plus municipal surcharge up to 1.5% and state surcharge on larger profits. Malta: 35% with up to 6/7ths refunded - around 5% effective on qualifying trading profits.

Personal tax. NHR closed to new entrants and IFICI covers a narrow set of roles. Malta’s non-dom remittance basis is default law for foreign residents - foreign income is taxed only if remitted, with no scheme expiry.

Certainty and language. Malta runs company law with strong common-law roots, English as an official language and a refund practice applied for decades - no quota rounds or regime renewals to track.

FAQ

Madeira also offers 5% - why bother with Malta?

Madeira’s MIBC rate is conditional: minimum job creation, investment thresholds, caps on the taxable base that enjoys 5%, and a regime window subject to EU approval cycles. Malta’s refund system is general law - no quotas, no headcount tests, no expiry date to diarise.

NHR is gone. What are internationals in Portugal doing now?

Three patterns: qualifying for IFICI where a role genuinely fits; accepting standard Portuguese progressive rates; or moving tax base - Malta’s non-dom remittance basis is the closest EU analogue to what NHR offered, without a scheme deadline.

Can I keep living in Portugal and run a Maltese company?

Sometimes - with real Maltese substance, defensible management-and-control and attention to Portuguese CFC rules. Sometimes the honest answer is to move yourself as well as the company. The memo tells you which case you are.

How fast can I act if Malta wins the comparison?

The memo takes days, not months. Implementation typically runs two to four weeks to an operating company, subject to KYC and banking.