Declaring bank accounts and income obtained outside Portugal with the IRS is a tax obligation that can catch many taxpayers off guard, especially those who live in the country but maintain financial connections abroad. The rule, according to the Tax Authority (AT), does not depend on nationality, but on tax residence in Portuguese territory.
Tax residents in Portugal, according to information available at , must declare to the IRS all income obtained, both in national territory and abroad.
This obligation is confirmed by the Income Tax Code and the Federal Revenue itself, which explains that residents must include Annex J in the Model 3 declaration when they have income obtained outside the country.
Rule applies to tax residents, not just Brazilians
The topic gained special attention among foreign citizens registered as tax residents in Portugal, including many Brazilians. Even so, the obligation is the same for any taxpayer residing in the country, whether Portuguese, Brazilian or of another nationality.
According to AIMA’s 2024 Migration and Asylum Report, Portugal registered 1,543,697 resident foreign citizens on December 31, 2024. The Brazilian community remained the main resident foreign community, representing 31.4% of the total, according to AIMA.
For tax purposes, the essential question is whether the person is a resident in Portugal. The AT indicates that tax residence may result, among other criteria, from staying in Portugal for more than 183 days, consecutive or interpolated, within a period of 12 months, or from the existence of housing in conditions that suggest the intention to maintain and occupy it as a habitual residence.
What must be declared in Annex J
Annex J of the Model 3 declaration is intended for tax residents who have income obtained outside Portugal. This includes salaries paid by foreign entities, pensions, income from self-employment, interest, dividends, rent for properties located outside the country, capital gains and other income from a foreign source.
The AT itself confirms that, in addition to the annexes relating to income obtained in Portugal, the taxpayer must include Annex J to declare income obtained abroad. The official instructions for Annex J, approved for the 2025 IRS declaration, indicate that this annex is intended to declare income obtained outside Portuguese territory by residents, according to .
The fact that the income has already been taxed abroad does not mean that it can be omitted in Portugal. The IRS explains that the tax paid in the country of origin can be taken into account as a tax credit for international double taxation, preventing the same income from being taxed twice, but the declaration remains mandatory.
Bank accounts outside Portugal also count
The obligation is not limited to income. Table 11 of Annex J serves to identify deposit or securities accounts opened in a non-resident financial institution in Portugal, or in a branch located outside Portuguese territory of a resident financial institution.
The General Tax Law (LGT) confirms this obligation in article 63-A, no. 8. IRS taxpayers must mention in the declaration the existence and identification of these accounts when they are holders, beneficiaries or are authorized to operate them.
This means that a deposit or securities account outside Portugal may have to be nominated even if it has not generated income. The IRS expressly clarifies that Table 11 must identify all deposit or securities accounts, even if they have not generated any income, as long as the taxpayer is the owner, beneficiary or authorized to operate them.
Relevant non-IRS deadline of 2025
For the Income Tax declaration submitted in 2025, relating to income from 2024, the general deadline was between April 1st and June 30th.
If the taxpayer has already filed a return without including foreign income or accounts covered by Schedule J, he or she may have to file a substitute return. The Income Tax Code also provides that the declaration must be presented within 30 days of the occurrence of an event that alters income already declared or implies, in relation to previous years, the obligation to declare them.
AT says that, within the scope of international cooperation in tax matters, it receives information communicated by foreign tax administrations about income obtained outside Portugal by people considered tax residents in Portuguese territory. Therefore, the omission of these income or accounts may end up being detected through automatic exchange of information.
In its frequently asked questions, the authority indicates that, when a taxpayer with tax domicile in Portugal does not declare income obtained abroad, they can send a communication informing the tax obligation to be fulfilled.
The same official information states that voluntary regularization can be done by submitting a substitute declaration with Annex J, when the initial declaration was presented without this annex.
How to check the situation
Anyone who received an alert must enter the Federal Revenue Portal, authenticate with CPF and password, and consult the alerts or electronic notifications area. From there, you must confirm whether you had foreign income or deposit accounts or securities outside of Portugal that require Annex J to be completed.
Regularization can be done online, by delivering or replacing the Model 3 declaration. In case of doubt about tax residence, the type of account, ownership or the existence of income subject to declaration, the taxpayer must confirm the situation directly on the Finance Portal or with a certified accountant, because the obligation depends on the specific facts of each case.
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