Moving to Portugal from Ukraine: 2026 Tax Checklist

If you arrived in Portugal from Ukraine — whether as a post-2022 TPS holder, on a D7 / D8 visa, as a relocated IT specialist on a contract, or as a retiree with property and a pension back home — you’re now in a country that taxes worldwide income. Your Ukrainian FOP earnings, your apartment in Kyiv, the UAH sitting in a frozen NBU-restricted account, the income from a remote contract paid into a Wise account — all of it has a place on the Portuguese IRS return, even when none of it physically arrived in Portugal.

This guide covers what to declare, when, and how the PT/UA Convention for the Avoidance of Double Taxation decides which country gets to tax what. Where there’s an established AT binding ruling for Ukrainians — most notably PIV 29518 on selling Ukrainian real estate under NHR — this guide cites it directly.

The PT/UA Convention - what it actually does

The PT/UA CDT is the bilateral treaty between Portugal and Ukraine that allocates taxing rights for residents of either country. It doesn’t reduce tax — it prevents the same income being fully taxed twice. The mechanism: one country has the primary right to tax; the other gives a credit for tax paid in the first.

The articles that come up most often for Ukrainian arrivals:

Article	Income type	Plain-English summary
Art. 4	Tax residency tie-break	If both countries claim you as resident, Convention rules pick one. Permanent home → centre of vital interests → habitual abode → nationality.
Art. 6	Income from real estate	Taxable where the property sits. Ukrainian rental → Ukraine can tax. PT also taxes (residence) with credit.
Art. 13	Capital gains on real estate	Same rule as Art. 6. PIV 29518 builds on this article for the Ukrainian-property-under-NHR case.
Art. 15	Employment income	Taxable where the work is physically performed. Move to PT and work remotely → PT taxes from day one of PT residence.
Art. 17	Pensions	Taxable only in the resident country (with limited exceptions for government service pensions covered separately). PT taxes your Ukrainian state pension.
Art. 10	Dividends	Source country can withhold at capped Convention rate. PT taxes at 28% with credit for Ukrainian tax already paid.
Art. 11	Interest	Same pattern as dividends, lower Convention withholding cap.
Art. 12	Royalties	Source country withholds at the Convention rate; PT taxes with credit. Often relevant for Ukrainian IT specialists with prior IP arrangements.

The exact article numbering follows the OECD Model that the PT/UA Convention is based on. Verify against the actual Convention text on AT before citing in your own filing or pedido de informação vinculativa. The full text in Portuguese is on AT’s site under Convenções para Evitar a Dupla Tributação → Ucrânia.

TPS / Temporary Protection ≠ tax residency

This catches almost every post-2022 Ukrainian arrival in PT, so it’s worth being blunt about:

Tax residency under Portuguese law is decided by CIRS art. 16, not by your visa or protection status. You’re a PT tax resident in any calendar year where:

• You spend more than 183 days in Portugal during the year, OR
• You spend 183 days or fewer but have habitual residence in PT (a permanent home available to you on 31 December)

Whether you’re on TPS (Tymchasovyi Protection / Proteção Temporária), a D7 visa, a D8 digital-nomad visa, or no specific status at all — none of those change whether you’re a tax resident. If you’ve been living in PT for more than half the year, you’re a tax resident, you have to file Modelo 3, and you have to declare worldwide income.

When does PT residence actually start?

For someone arriving in the middle of a calendar year, the practical question is: which calendar year is the first one I file Modelo 3 for, and what about the period I was still in Ukraine?

Two paths:

• Arrived before 1 July of a given year — you’ll exceed 183 days by year-end, so you’re PT-resident for the whole calendar year. Modelo 3 covers all worldwide income from 1 January.
• Arrived after 1 July — you may or may not exceed 183 days. If your permanent home is now PT (rented apartment with a lease, family present), CIRS art. 16’s “habitual residence” arm catches you and you’re a resident for the year. If you arrived very late (October, November) and could plausibly argue your permanent home is still elsewhere, the call is closer.

For income earned in Ukraine before you became PT-resident, the Convention’s tie-break (Art. 4) applies. In practice, with proper documentation (lease start date, registration of fiscal address, family arrival), the pre-PT period is treated as Ukrainian-resident and not PT-taxed.

For a clean transition: document your arrival date, register your fiscal address (morada fiscal) at AT promptly via the fiscal-address guide, and keep a paper trail (flight tickets, lease, utility connection dates).

Path A - Ukrainian FOP income and remote work

The big one for the Ukrainian IT community in PT.

FOP (Фізична Особа-Підприємець) is the Ukrainian sole-proprietor entity. Single-tax (Group 3) FOPs pay 5% Ukrainian tax on revenue (or 3% + VAT if VAT-registered — the 5%, non-VAT setup is the typical IT case) with relatively light reporting. The arrangement is administratively cheap but does not transplant to Portugal — once you’re a PT tax resident, the FOP doesn’t shield you from PT income tax on the same earnings.

You have three practical options:

A1. Switch to recibos verdes in Portugal (most common)

Open a PT freelancer registration with AT, become a trabalhador independente, and invoice your clients as a PT freelancer. You can either close the FOP or leave it dormant in Ukraine — it doesn’t help you in PT either way.

Workflow:

1. Open activity at Finanças (recibos verdes)
2. Issue your first invoice
3. Register with Segurança Social as a trabalhador independente
4. File Modelo 3 with Anexo B for the simplified regime (0.75 coefficient for professional services)
5. Quarterly SS contributions; annual IRS

This is the cleanest setup for most IT freelancers. See first-year recibos verdes guide for the full timeline.

A2. Keep the FOP and declare the income on Anexo B in PT

Technically possible. You keep invoicing through your FOP in Ukraine, pay 5% Ukrainian single tax, and also declare the same income on Anexo B of Modelo 3 in PT as foreign self-employment. PT taxes at progressive brackets minus a foreign-tax credit for the Ukrainian 5% (under Art. 15 of the Convention, work performed in PT is PT-taxable; the Ukrainian tax becomes a credit).

This is administratively heavier (two countries’ books to keep) and usually doesn’t save tax versus A1, because the 5% credit is small relative to the PT progressive bill. Some Ukrainian freelancers prefer this anyway because the FOP is their existing infrastructure — Ukrainian payment processors (LiqPay, Privat24) that their clients are already set up to pay through.

A3. Employer-of-Record arrangement

If your client is a single foreign employer (US, UK, EU SaaS company) treating you as an employee, an Employer of Record (EOR) like Deel, Remote.com, or Velocity Global can put you on a PT payroll. You become an EOR-employed Cat A salary earner in PT. Cleaner for the employer side, slightly more expensive in fees.

Path B - Ukrainian pensions

Under Art. 17 of the PT/UA Convention, Ukrainian pensions are taxable only in Portugal once you’re PT-resident. Practical steps:

Path C - Ukrainian real estate (and PIV 29518)

This is where the most specific Ukrainian-PT precedent applies.

C1. Rental income from Ukrainian property

Under Art. 6, Ukraine has the right to tax rental income on Ukrainian property (it’s Ukrainian-source). In practice, you may or may not be filing in Ukraine for that rental — wartime conditions have made Ukrainian filing impractical for occupied territories or where tenants have fled. Portugal as your residence country still taxes the same rental on Quadro 7 of Anexo J, and you claim a credit for any Ukrainian tax paid.

Declare gross rental (converted to EUR at the official annual rate), then claim PT-recognised expenses under CIRS rules. Net rental goes to either 28% flat (default) or progressive brackets (englobamento election).

C2. Selling Ukrainian real estate as a PT tax resident - PIV 29518

This is the headline insight for Ukrainians who have moved to PT and are considering selling property back home.

PIV 29518 is an AT informação vinculativa (binding ruling) that addresses exactly this case: a Portuguese tax resident under NHR sells real estate located in Ukraine. The ruling establishes:

• The gain is covered by Art. 13 of the PT/UA Convention (capital gains on immovable property)
• Both countries have taxing rights, with PT giving a foreign-tax credit
• Under NHR, the foreign-source capital gain on real estate can be exempt in PT if the source country has the right to tax it under the bilateral Convention (regardless of whether Ukraine actually levied tax on the transaction)

Conditions stated in the ruling:

• Seller is a PT tax resident
• Seller has active NHR status
• The asset is physical Ukrainian real estate (not a Ukrainian holding company)
• Seller is an individual (not a corporate vehicle)
• The transaction is properly declared on the PT IRS return

Important limit: PIV 29518 is binding only on AT, only for the person who filed it. It’s persuasive precedent for anyone in the same situation but not automatically binding for your case.

C3. Inherited Ukrainian property

Inheritance is taxed in Portugal differently from sale — there is no Portuguese inheritance tax for direct relatives (parents, children, spouse). For other relatives or unrelated heirs, Imposto do Selo at 10% applies on the value transferred. However, once you’ve inherited a Ukrainian property and then sell it, the C2 treatment kicks in (Art. 13 + PT residence taxation).

If you inherited Ukrainian property during a wartime period, document the inheritance carefully (Ukrainian notary records, court rulings if applicable) — AT may ask for the cost basis at the inheritance date to calculate any subsequent capital gain.

Path D - Ukrainian banking and currency controls

NBU (National Bank of Ukraine) wartime restrictions limit how much UAH you can transfer abroad. Many Ukrainian arrivals in PT have meaningful UAH balances that they cannot move out of the country.

The PT tax position is straightforward and counterintuitive: Portugal taxes worldwide income for residents. Income earned in UAH, sitting in a UAH account you can’t transfer, is still PT-taxable income in the year it was earned or made available to you.

What’s not PT-taxable: capital that was already yours before becoming PT-resident. Pre-residence UAH savings remain pre-residence capital — they don’t generate new tax liability just because you became a PT resident. Only the income earned on those balances (interest, etc.) becomes PT-taxable post-residence.

For declaring the UAH income, convert to EUR at the official AT exchange rate for the year, declare on the relevant Anexo J quadro based on income type (Quadro 6 for interest, Quadro 4 for salary, Quadro 7 for rental, etc.).

Path E - Ukrainian-issued equity / RSUs

Less common but worth mentioning for those who worked for Ukrainian tech companies that grant equity.

The treatment is the same as the UK→PT case: workday apportionment of any RSU vest spanning the move. The portion earned during Ukrainian workdays is Ukrainian-source (Art. 15); the portion earned during PT workdays is PT-source. If the company doesn’t operate a PT payroll, the PT portion lands on Quadro 4 of Anexo J as foreign Cat A salary.

For shares held outright (not RSUs), any sale gain after becoming PT-resident is a capital gain — Quadro 8 of Anexo J at 28% flat or progressive via englobamento.

NHR / IFICI / standard - which regime fits a Ukrainian arrival?

Year you became PT-resident	Eligible regimes
Before 2024	NHR (if registered in time) + standard. NHR is favourable for foreign pension and certain foreign passive income.
2024 onwards (the typical post-2022 arrival case)	Standard + IFICI (if your work qualifies). NHR is closed to new applicants.

For a typical post-2022 Ukrainian arrival registering as PT-resident in 2024 or later: NHR is not available. You’re either on standard rates (default) or IFICI (only if your work qualifies — narrow scope, see the eligibility checklist).

For Ukrainian IT specialists:

• General software development: usually doesn’t qualify for IFICI. Standard regime.
• R&D, AI/ML research, work on patentable innovations, academic-adjacent roles: may qualify. Worth checking with the IFICI eligibility checker.
• Working for a Ukrainian R&D centre while in PT: this is a nuanced case; the work needs to be qualifying and the engagement structure needs to support the IFICI declaration. A contabilista familiar with cross-border IFICI cases is worth consulting.

The standard regime at 2026 rates is more competitive than expat forums sometimes suggest — bracket cuts from OE 2026 reduced rates in the middle brackets, and the family quotient is generous for sole-earner couples with dependents.

For a head-to-head with Ukrainian taxation, the comparison is less established than UK / US / EU comparisons because Ukrainian tax law has changed substantially since the war. Expect a TAXCLARA Ukraine-vs-Portugal comparison guide later in 2026.

When to file your own pedido de informação vinculativa

A pedido de informação vinculativa (PIV) is a binding ruling from AT on how a specific situation in your name will be taxed. The PIV 29518 example above is the most cited Ukrainian-PT case. Worth filing your own if:

• You’re selling Ukrainian real estate of any meaningful size (recommended above)
• You’re carrying forward Ukrainian losses (less common, treatment unclear)
• You inherited a Ukrainian asset under specific wartime documentation circumstances
• You’re a TPS holder with an unusual past-year filing pattern who wants to lock in their current treatment before AT decides retroactively
• You have substantial UAH-denominated assets and want clarity on when income is “received” for PT purposes (cash basis vs. realisation question)

Cost: free to file online via Portal das Finanças. Response time: 4-6 months typically. Filing one only protects you - not your spouse, not anyone else with similar facts.

Common mistakes Ukrainian arrivals make

Assuming TPS exempts them from PT tax filing. Covered above. Single most common error and the one with the longest-tail compounding cost.

Not declaring FOP income because it was earned in Ukraine. Once PT-resident, your worldwide income is PT-taxable — including Ukrainian FOP earnings. Even if you’ve paid the 5% Ukrainian single tax, you must declare in PT and claim the credit.

Treating frozen UAH as “not counting.” Covered above. Income earned in UAH is PT-taxable even if you can’t move the cash out of Ukraine.

Wrong currency conversion rate. AT publishes official annual rates for tax years. Use those, not your bank’s rate, NBU’s rate, or the rate on the day you happened to check XE.com. The difference is usually small but auditable.

Missing the NHR window. If you arrived in 2023 or earlier and never registered for NHR, the window may have closed for you. Check with AT whether you had a valid window between your residence date and the 2024-01-01 cutoff. Some 2023 arrivals could still register under transitional provisions through October 2024 — and if you missed that, the door is now closed.

Filing only Ukrainian returns, not PT. Many post-2022 arrivals continue filing in Ukraine (where required) and skip PT entirely. This creates a missed-filing gap that grows annually. The fix: catch up on past-year PT filings through a contabilista, accepting some penalties for late submission. Almost always cheaper than waiting for AT to notice.

When to hire a cross-border specialist

DIY filing of Anexo J is doable for simple cases: a single income source, clean UA→PT relocation, no property, no inheritance complications.

Get a specialist for:

• Selling Ukrainian real estate of any meaningful value (PIV recommendation above)
• Past-year filing gaps (especially TPS holders catching up on 2022-2024)
• Inherited Ukrainian property with wartime documentation
• FOP-to-recibos-verdes transition year with mixed income sources
• Children’s education / family quotient interaction when the family arrived in stages

Costs: roughly €500-€2,000 for a clean UA→PT transition year, less in subsequent steady-state years. Lisbon has a small number of contabilistas with Ukrainian-language capacity plus PT cross-border expertise — ask in the Ukrainian IT community for current recommendations.

Sources

• List of Conventions to Avoid Double Taxation — AT portal — find Ucrânia in the list for the direct link to the Convention text
• AT informações vinculativas database — search code 29518 for the full text of the Ukrainian-real-estate-under-NHR ruling
• CIRS art. 16 — tax residency
• CIRS art. 81 — foreign-tax credit
• Pension Fund of Ukraine — pensions paid abroad
• NBU — currency restrictions and exchange-rate policy
• Foreign-Source Income on Anexo J - mechanics of declaring foreign income
• Recibos verdes first-year guide
• IFICI Portugal application guide - if your work might qualify
• NHR vs IFICI vs standard regime

This is a heads-up guide, not a substitute for personalised advice. Your specific situation will have details that change the answer - especially around past-year filing gaps and Ukrainian real estate timing. If you spot something out of date or incorrect, email hello@taxclara.pt and we’ll fix it.