Registration of an investment fund in Portugal

Legal regulation when setting up investment funds in Portugal

Registering an investment entity in Portugal requires a management firm with a valid Comissão do Mercado de Valores Mobiliários licence. It interacts independently with the regulator and is responsible for the registration of the fund, its day-to-day operations and disclosure of information to investors. The organisation also monitors compliance with investment restrictions:

• Checks the eligibility of each asset before purchasing.
• Monitors compliance with limits on the proportion of assets in the portfolio.
• Monitors the effect of restrictions by investment type.
• Ensures compliance of the asset structure with the approved investment policy.
• Monitors compliance with the fund's liquidity norms.

An entrepreneur cannot independently contact the regulator or make changes to the fund: any requests, adjustments and reports go only through the management company. There are two options for registering an investment fund in Portugal:

• Contract with an already licensed management company (hire an intermediary) and entrust the process to them.
• Set up your own management company to have 100% control over every step of the process.

Working through an existing manager reduces the registration of the investment entity in Portugal to 2-4 months (if the documents are submitted correctly and there are no complications). The entrepreneur is exempt from contributing minimum capital (from 125,000€), organising internal controls, hiring mandatory staff and regulatory reporting. These functions are fulfilled by the management company.

However, establishing an investment firm in Portugal through an intermediary introduces additional risks and reduces direct control. The fund becomes entirely reliant on the management company, which acts as the sole point of contact with the CMVM and is responsible for regulatory compliance, reporting, and any structural changes. The quality and long-term stability of the fund are closely tied to the competence and reliability of the chosen manager. Moreover, replacing the intermediary involves a complex bureaucratic process and requires formal approval from the regulator, making changes both time-consuming and potentially disruptive.

Setting up an in-house management company requires the preparation of an internal compliance system and CMVM licensing. The process takes 6 to 12 months and involves additional requirements:

• Registration of a separate legal entity.
• Hiring two directors with proven experience, a compliance officer, a risk manager and an auditor.
• Compliance with capital ratios and internal controls.

This route gives full control of the fund but significantly increases the time and cost of launching the project. It is justified in the following scenarios:

1. Significant amounts or several funds are under management at the same time. The larger the volume of assets, the more rigorous the CMVM checks the manager's work. An in-house organisation accelerates the adaptation of internal processes to the requirements of the regulator without dependence on a third-party structure.
2. There are plans to attract large investors and enter international EU markets. Registration and servicing of investment entities in Portugal through its own licence strengthens the confidence of institutional investors, simplifies obtaining the status of UCITS- or AIF-fund with subsequent expansion.
3. Full control over investment policy and operations is required. Relevant for funds with non-standard investment strategy, frequent changes in the fund structure or a narrow circle of investors.

To register an investment fund in Portugal and to operate it, it is necessary to hire a depositary. This is an auditor who controls the admissibility of the assets purchased, the control of investment limits and the correct calculation of the net asset value (NAV). If irregularities are detected, it directly notifies the CMVM regulator, regardless of the management company's actions or the entrepreneur's decisions.

The depositary ensures dual control: even if the fund owner decides to conceal information, the regulator will still learn about it from the independent auditor.

The CMVM regulates investment entities through management firms, which are fully liable for all violations related to the management of the fund. Including disclosure of information, non-compliance with the asset structure, violation of compliance rules or deviation from the approved investment policy.

Once an investment entity is opened in Portugal, it is impossible to distance oneself from the problems of the manager: mistakes by the intermediary can lead to reputational consequences, financial losses and blocked operations. In case of serious violations, the CMVM imposes sanctions:

• Restricts the fund's right to attract new investors.
• Freezes asset transactions.
• Appoints an external administrator to enforce control.
• Revokes the management company's licence.

If, after registering an investment fund in Portugal, the management company loses its licence, the regulator prohibits any activity. All fundraising operations and payments to investors are frozen. The entrepreneur must, within 30-60 days, find a new licensed intermediary, obtain CMVM approval for the transfer of the fund and conclude a new contract.

The transfer of the fund takes a minimum of 2-3 months, even if the parties co-ordinate quickly. If a new manager cannot be found, the fund is subject to compulsory liquidation. In this case, the assets are sold, settlements with investors are made through a special administrator, and the entrepreneur loses the project without the possibility of restoring the fund to its former structure.

The entry of investment funds into international EU markets is also regulated by the CMVM through a management firms.

• UCITS funds receive an automatic passport: after notifying the CMVM, they can place units in other countries without a separate licence. The process takes 1-2 months.
• Alternative funds (AIFs) undergo a separate notification in each country. The process takes 3 to 6 months, requires localised documents and additional requirements.

Before registering an investment fund in Portugal, you should make plans in advance to expand to other EU markets. UCITS provide faster and cheaper progression, while an AIF allows you to invest in a wider range of assets including:

• Real Estate.
• Start-ups and venture capital projects.
• Loans.
• Cryptoassets

CMVM sets minimum disclosure standards for all investment entity. The management company is required to regularly publish net asset value, list of underlying investments, changes in investment policy and current strategy risks. The data is disclosed publicly to investors and submitted to the regulator for control.

UCITS and AIF: the main options for registering an investment fund in Portugal

The selection of the fund type is a critical decision that influences the permitted asset composition, target investor base, and access to international markets. UCITS funds are designed for retail investors and offer broad market access but impose strict restrictions on fund types and liquidity requirements. In contrast, AIFs provide greater flexibility, allowing investments in startups, real estate, loans, and crypto-assets; however, they are reserved for professional investors. Choosing the wrong structure can complicate the registration process of an investment fund in Portugal and significantly constrain future business growth.

Opening UCITS funds in Portugal

The Undertakings for Collective Investment in Transferable Securities format is designed to work with private investors in the EU. It allows units to be sold freely to individuals without obtaining separate licences in each offering country. It is chosen by most projects targeting the mass market.

Opening a Portuguese UCITS fund imposes strict requirements on the asset structure and management strategy. The regulator only allows investments in liquid financial instruments:

• Shares in companies listed on recognised stock exchanges.
• Government and corporate bonds.
• Money markets and mutual funds subject to UCITS standards.

Direct investments in property, start-ups, private loans, crypto-assets and other illiquid assets are prohibited. Such investments are considered inconsistent with the liquidity requirements and daily valuation of units.

Once the UCITS investment entity is registered in Portugal, portfolio structure limits must be observed:

• No more than 10 per cent of assets may be invested in one issuer.
• Aggregate investments in securities of one issuer and related instruments must not exceed 20% of the fund's assets.
• A minimum diversification of assets must be maintained at all times.

Every day, the management company must calculate the fund's net asset value (NAV) and allow investors to purchase or redeem units at a fair market price. The fund's assets must be liquid to such an extent that redemption of the liabilities is possible on any business day.

Opening a UCITS fund in Portugal allows units to be placed in other EU countries without separate licensing (it is sufficient to notify the CMVM and the regulator of the promoting country). The registration procedure takes 1-2 months, and the status frees from the creation of local structures and reduces legal costs when entering a new market. The fund gains access to both retail and institutional investors throughout the EU zone.

However, operating in the UCITS format limits investment strategies. The Fund may not:

• Concentrate assets in a single facility or project
• Invest in long-term illiquid assets with a focus on high returns.
• Deviate from portfolio liquidity requirements throughout the course of operations.

The establishment of UCITS funds in Portugal excludes investments in real estate, venture capital projects or alternative assets.

Registration of an alternative investment fund in Portugal

This format is ideal for investment projects that fall outside the scope of UCITS funds, such as real estate, direct business financing, venture capital, and crypto-asset management. An AIF offers greater flexibility in portfolio composition, allowing investments in illiquid or high-risk assets. It is specifically designed for professional investors and imposes no strict limitations on the structure of investments, making it a suitable vehicle for complex and non-traditional investment strategies.

After registering an alternative investment entity in Portugal, an entrepreneur is able to:

• Acquire commercial and residential property for rent, sale or development.
• Invest in start-ups at any stage of development, including venture capital funding.
• Make private loans to businesses and structure debt transactions.
• Build portfolios of crypto and tokenised digital assets.
• Participate in other alternative funds.

The fund is not required to meet daily liquidity standards or strict asset diversification. It can concentrate capital in individual projects, build a portfolio around one industry or one type of assets without quantitative restrictions (if it is fixed in the fund's policy).

The sale of fund units is available only to qualified investors - legal entities or individuals who fulfil one of the following criteria

• The investment portfolio exceeds 500,000€.
• Contribution to the fund is 100,000€ or more.
• Meet investment experience requirements (e.g. at least one year in finance).

To set up an AIF fund in Portugal, an investment risk management policy must be approved, with regular review when the strategy changes. Internal compliance will need to be established to control limits and transactions, and a contract with a licensed depositary responsible for verifying custody of assets, compliance with the investment policy and calculation of NAV.

Entering the EU markets through an AIF requires separate notification to the regulators of each country. The procedure takes between 3 and 6 months and includes filing a compliance package to meet local marketing, disclosure and investor protection requirements. Registration costs are increased compared to UCITS as each country has different eligibility conditions.

Setting up an AIF fund in Portugal is justified for the following types of projects:

• Property funds with a focus on rental or development.
• Venture capital funds to support technology start-ups.
• Structures for corporate loans.

And crypto funds to invest in digital assets and tokens.

Specialised AIFs in Portugal

Specialised Funds (REIF, VCF, PEF, Credit Fund, FIAE) are a type of Alternative Investment Funds (AIF) in Portugal designed to deal with a predefined asset type or investment strategy. Unlike universal AIFs, they operate within standardised regulatory parameters approved by the CMVM.

In this scenario, the registration of an investment fund in Portugal follows a simplified procedure: the regulator has fixed in advance the permissible types of assets, transaction structure, valuation methods and income model. This reduces the amount of documentation, eliminates the need for legal justification of the strategy and shortens the registration period to 1.5-2 months. Additionally, legal support costs are reduced due to the exclusion of individual expertise of each component.

A management firms may use SPV structures if they are fully controlled by the fund and applied strictly within the framework of the approved model. The only restriction is the inability to deviate from the chosen direction: all investments must comply with the declared category of the fund.

Registration of the Portuguese Real Estate Fund (REIF)

The format is designed for direct and indirect investments in real estate: residential, commercial or mixed. It is allowed to acquire ready-made properties, participate in projects under construction, purchase land for development and finance renovations (provided that the fund retains investment control).

Opening an investment fund in Portugal (REIF) allows you to generate income under several scenarios:

• Rental model: buying properties with existing rental contracts (including through SPVs) and receiving regular payments.
• Development: construction or redevelopment followed by capitalisation of the cost and exit from the project.
• Speculative resale: buyout at undervalue with subsequent realisation.
• Dividends from operating companies: if the property is owned by a business, the fund may receive income through profit participation in the SPV managing the asset.

CMVM requires an annual independent valuation of all properties with the results disclosed in the fund's accounts. Only regulator-approved methodologies are acceptable: income, comparative or cost approach. A departure from the starting income model is considered a change in investment policy and requires re-approval.

Before registering an investment fund in Portugal (REIF), it is necessary to take into account the format restrictions:

• Investments in non-financial assets other than real estate are not allowed.
• A minimum of 75% of the fund's assets must be invested in physical assets.
• CMVM requires ongoing compliance with an approved model, including when using SPVs.

The REIF format is appropriate for projects with a clear income model and a predefined asset category.

The format is designed to invest in start-ups and high-growth potential companies at an early or expanding stage of development. Pre-seed, seed, Series A-C and later rounds are allowed, including convertible instruments and equity options.

VCF registration in Portugal allows for one or more of the following exit models:

• Sale of stake to a strategic investor or other fund.
• IPO or partial flotation on a venture capital exchange.
• Buyback by the founders or parent company.
• Liquidation of the SPV with distribution of assets.

Income is generated from share appreciation, dividends (if applicable), and a priority return if the fund receives special exit rights. CMVM requires each investment to comply with pre-approved policies:

• Acceptable industries.
• The stage of development.
• Deal structure.

The fund may not deviate from these parameters without obtaining separate approval.

The regulator requires active control over investments. The management firms must participate in strategic decisions, evaluate KPIs of the recipient companies and disclose the current status of the investments in reports. Before registering a venture capital fund in Portugal (VCF), a number of restrictions must be taken into account:

• No investment in liquid market instruments is allowed, except for the placement of free funds in highly liquid assets with a short maturity (e.g. government bonds or demand deposits).
• The fund must observe a minimum holding horizon (typically 3-5 years).
• CMVM may require documentation of the management company's venture capital competence.

The VCF format is suitable for projects focused on capital growth through high-risk investments. It requires a clear exit strategy, continuous monitoring of assets and professional management at all stages of the life cycle of portfolio companies.

The format is designed to acquire stakes in private companies for the purpose of subsequent sale, restructuring or consolidation. CMVM allows investments in mature businesses, including M&A transactions, buyout of controlling stakes and participation in business transformation. After opening a PEF fund in Portugal, the following exit strategies can be used:

• Selling a stake to a strategic investor.
• Attracting a financial investor in the next stage.
• Converting to a public company through an IPO or listing.
• Selling the business in preparation for a merger or realisation of a group of companies.

CMVM requires each investment to follow a pre-approved strategy: by industry, jurisdiction, share size and holding period. The management company is required to provide a rationale for the investment decision, a value growth model and an exit scheme. Passive ownership is not permitted: the fund must participate in management, including control of key decisions, board appointments and strategic changes.

Income is generated from business value growth, dividend payments (if applicable) and profit distributions on the sale of a share. CMVM requires periodic reassessment of the value of stakes using recognised corporate methodologies (DCF, EBITDA multiples, peer transactions), with disclosure in regular reporting. If there is a significant change in the business structure or a deviation from the initial plan, re-approval by the regulator is required.

Before registering a private equity fund in Portugal (PEF), there are a number of requirements to consider:

• The fund must retain influence over the strategy of the recipient company.
• Transactions cannot be purely financial or speculative in nature.
• CMVM is entitled to request information on the composition of the team, its experience in transactional and operational management.

The PEF format is suitable for projects focused on active business operations, operational efficiency growth and preparation for sale.

The format is designed to provide private loans to companies without the involvement of traditional banks. CMVM authorises lending to corporate clients, including working capital financing, project lending, factoring, forfeiting and bridge financing. Permitted to target one or more segments:

• SMEs.
• Development projects.
• Infrastructure.
• Export-import operations.

CMVM requires that borrower categories, types of loans, collateral structure, permissible terms and rates be determined in advance. All parameters of the lending policy are fixed in the investment declaration and are subject to verification at the time of fund registration.

After opening a credit investment entity in Portugal, income is generated through interest payments, fees, early repayment fees or equity participation options of the borrower. CMVM requires risk assessment at the level of each transaction, a scoring system, clear underwriting and monitoring procedures. The management company is required to internally classify assets, record delinquencies and regularly report on portfolio quality.

The Fund may not issue loans to individuals and may not accept deposits. It is also prohibited to concentrate more than 20% of assets on a single borrower (except for individually approved projects). CMVM monitors the compliance of the credit policy with the stated model and has the right to request documentation on any transaction.

Before opening a credit fund in Portugal, you should consider:

• CMVM requires a transparent risk management and internal control system.
• To register a fund, you need a credit model that is supported by the experience of the management team.
• The fund's return must be justified by calculations for a base and stressed repayment scenario.

The format is suitable for structures that focus on providing funding for operational or project purposes.

The format is designed for investment projects in sectors not covered by other specialised funds:

• Infrastructure.
• Agribusiness.
• Energy.
• ESG initiatives.
• Water and land resources.

As well as waste recycling, digital economy and other sector-specific projects. Participation in operating companies and in projects at the start-up or development stage is allowed. The management firm must describe in advance the industry focus, asset types, revenue model and exit parameters. The CMVM assesses whether the strategy complies with the FIAE format and has the right to refuse registration if the project does not fall under the specialised category.

Before opening a FIAE fund in Portugal, an entrepreneur should take into account:

• CMVM requires a precise and detailed description of the investment model - general plans and vague strategies are not accepted.
• The fund cannot arbitrarily change direction without re-agreement.
• The management company must prove experience or expert access to the industry in which the investment is targeted.

FIAE allows the launch of an investment structure that does not fall under the REIF, VCF, PEF or Credit Fund formats, but requires in-depth preparation and meaningful work with CMVM at registration.

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How much does it cost to set up an investment entity in Portugal

Regardless of the format, the entrepreneur will have to pay for filing the documents and registering the fund in the CMVM registry (approximately 1,500-3,000€). Other mandatory costs:

• Advance remuneration to the depositary: on average 3,000-7,000€ for the first year.
• Preparation and harmonisation of documentation, including fund regulations, investment policy, NAV calculation model and risk profile.
• Audit and support costs (if not included in the management company's tariff).

The management company's fee for setting up an investment fund in Portugal and communicating with the CMVM is usually between €5,000 and €15,000. The amount depends on the specialisation and the amount of assets. You will also have to pay:

• Notarisation and legalisation of documents.
• Opening a bank account
• Legal support.
• Harmonisation of the investment model, participation structure and SPV.

To create an AIF-fund in Portugal you will need 15,000-30,000€, for a specialised AIF (REIF, VCF, PEF, etc.) - from 10,000 to 20,000. UCITS-funds are more expensive (from 25 000€) due to the preparation of KIID and more stringent requirements to documents and asset structure.

CMVM does not impose a minimum authorised capital requirement, but the management company may do so. To confirm the willingness of investors to fund the structure in the first months, 100,000-150,000€ is usually required (especially in the case of AIF).

When setting up an investment fund in Portugal with a cryptocurrency, venture capital or credit profile, the costs increase by 5,000-10,000€. The funds are spent on developing individual risk management policies and undergoing additional approvals from the CMVM.

Contracting a management firm

When setting up an investment entity in Portugal, most entrepreneurs contract a third-party management company. Creating your own organisation with a CMVM licence is economically justified when managing tens of millions of euros. For smaller volumes, the annual staffing, auditing, licensing and compliance costs (from 250,000€ on average) exceed the commission of the third-party entity. Therefore, only the first option is considered in this article.

Before choosing a management firm, that it has a CMVM licence to manage funds of the appropriate type (UCITS or AIF). It should have two directors with relevant experience, a compliance officer, a risk manager and an internal auditor.

Information on licensed management companies is published in the official register on the CMVM website (section "Entidades Autorizadas"). The card of each company indicates the authorisations in force, the areas of activity and the applicable restrictions.

When setting up a Portuguese investment fund through a third-party manager, the entrepreneur must:

• Provide a detailed description of the investment model, asset types and target structure of the fund.
• Confirm the origin of the funds (AML/KYC documents).
• Specify the intended investor categories (retail, professional).
• Sign the fund establishment agreement and the agreement on the transfer of functions to the manager.

The CMVM has the right to request from the management company information about the beneficiary of the fund and confirm its compliance with the requirements for a qualified investor. If an SPV is used, the entrepreneur must disclose the ownership structure, control arrangements and the legal basis for the establishment of the subsidiary.

A change of management company must be approved by the CMVM and typically takes 2–3 months to complete. The process is only permitted if a valid agreement is in place with the new management company, the depositary has given its consent, and all regulatory requirements are met. If the CMVM identifies potential risks to investor protection or deems the new structure unstable, it has the authority to deny the request.

Documents for registering an investment fund in Portugal

The documents for setting up an investment entity in Portugal are drawn up by a management company. At the first stage, it requests the following information from the entrepreneur:

• Type of fund (UCITS or AIF), investment strategy and asset classes: bonds, real estate, start-ups, crypto-assets, etc., as well as investment objectives, intended fund size and working currency.
• Target audience and geography: retail or professional investors, planned countries of unit distribution (Portugal, EU, other jurisdictions).
• Supporting documents: copies of passports and corporate documents, investor qualifications (if required), sources of funding for the fund.
• Participation structure: data on the initiator, the composition of the founders and beneficiaries, as well as the distribution of roles and rights between them.
• Organisational parameters: selected or proposed depositary and auditor, desired NAV calculation regime, liquidity requirements and reporting frequency.

Based on the collected data, a complete package of papers is prepared for the registration of the investment fund in Portugal. The main document is the regulations (Regulamento do Fundo de Investimento). It defines the objectives of the fund, the type of assets, the terms of working with investors, management rules and mechanisms for assessing the value of assets. It must be signed by the entrepreneur (as a founder or initiator).

Equally important is the financial model (Modelo Financeiro do Fundo). It contains return projections, cost structure, income generation mechanism and key parameters of the investment strategy. The regulator also requires a Depositary Agreement, which defines the degree of control over the admissibility of assets, compliance with the investment policy, and the correctness of the NAV calculation.

When registering an investment fund in Portugal, the management company prepares other documents:

• Declaração da Política de Investimento: a description of the admissible asset classes, geographical and sector coverage, concentration limits and rebalancing models.
• Metodologia de Avaliação de Ativos e Cálculo do NAV: methods for valuing assets and calculating net asset value (NAV), including frequency, price sources.
• Política de Gestão de Riscos: risk management system, limits, stress testing methods and internal control procedures.
• Organograma Operacional do Fundo: diagram of the operational structure of the fund. Covers SPV participation (if applicable), role of affiliates, decision-making and accountability chain.
• Declaração de Conformidade Regulatória: confirmation of compliance with CMVM requirements on marketing, investor structure (retail or professional), disclosure form and liquidity.

For UCITS funds in Portugal, the Documento de Informação Fundamental para o Investidor is additionally provided. This is a guide for investors, including a description of the strategy, risk levels, costs and historical/expected returns. It is mandatory to be published prior to unit allocation.

To open an AIF fund in Portugal with a clear specialisation (REIF, VCF, PEF, Credit Fund, FIAE), the following papers will be required:

• Justification for the choice of fund type within the categories approved by the CMVM.
• Evidence of compliance with the pre-established model (asset type, transaction structure, valuation).
• Additional calculations and risk profiles if the fund operates in the areas of real estate, lending or venture capital.

Important: the entrepreneur does not deal with the documents directly, but provides the information. He also signs the contract of establishment and draft regulations of the fund, the agreement with the management firm, and the documents on the commencement of operations (once the registration of the investment fund in Portugal is finalised).

Registration of an investment fund in Portugal: procedure and the role of the entrepreneur

Although the registration of an investment entity in Portugal is handled by a management company, the entrepreneur is involved in all key stages and is responsible for the completeness of the data provided. The registration period depends on the type of fund: from 1.5 to 3 months for standard UCITS and AIFs, from 1 to 2 months for specialised AIFs (REIF, VCF, PEF, etc.).

The first stage is the submission of the application to the regulator. The entrepreneur must sign the final version of the regulations and accompanying documents (agreement with the manager, agreement on the establishment of the investment fund in Portugal). He is also required to:

• Confirm the investment strategy, the list of assets, the target size of the fund and the circle of investors.
• Clarify the ownership structure: list of founders, distribution of shares, information on ultimate beneficiaries.
• Provide all documents on the sources of funding, including statements, declarations or contracts (at the request of the management company).

If there are SPVs, it is necessary to disclose the legal basis for their establishment, as well as the structure of subordination to the fund.

Once the application for the establishment of an investment entity in Portugal has been submitted, the audit begins. The CMVM checks the structure and objectives of the fund, the admissibility of assets and investment strategy, and whether the management company has the resources and authority to implement the model. The regulator also assesses the transparency of the ownership structure, the sources of funds and the appropriateness of the investor category.

If the CMVM has questions, it asks them through the management company. Clarifications, supporting documents or corrections may be required from the entrepreneur. Primarily the sources of funds, the economic substance of the structure, the composition of the investors and the role of the SPV. The fund initiator provides the data to the intermediary without contacting the regulator.

In the absence of complications, the CMVM approves the creation of the investment fund in Portugal and enters it in the official register. The management firm notifies the entrepreneur and co-ordinates:

• Signing the declaration of commencement of operations (Declaração de Início de Atividade).
• Opening a separate bank account for the fund (if not already formalised).
• Removal of the final obstacles to start operational work to attract investors and implement the strategy.

The quality and completeness of information for the regulator, directly affects the timing and the final decision. CMVM checks not only the documents, but also the logic of the model, its feasibility and transparency. Whether the fund is registered in 6 weeks or 4 months depends on the preparedness of the initiator.

Tax obligations after registration of an investment fund in Portugal

Once an investment entity is established in Portugal, the organisation is an independent taxpayer and the tax burden depends on the structure and format chosen.

Corporation tax (CIT)

The basic rate is 21%. There is an additional municipal tax of up to 1.5% and a state surcharge (derrama estadual) for large foundations:

• 3% on profits between €1.5 million and €7.5 million.
• 5% on profits between €7.5 million and €35 million.
• 9% on profits above €35 million.

For foundations registered as small or medium-sized enterprises (PME) with an annual turnover of up to €50 million, a rate of 17% applies on the first €50,000 of taxable income. To benefit from the incentive, it is necessary to operate in Portugal and fulfil the tax residency requirements.

Payments of income to non-residents are subject to withholding at source (WHT). The general rate is 25% but can be reduced by DFT agreements or EU directives. Applicable to dividends, interest, royalties.

For example, dividends between EU companies can be taxed at a zero rate if the participation conditions are met (minimum 10% share for more than 12 months). The same logic applies for interest and royalties if related persons within the European Union are involved.

Conclusion

Registering an investment fund in Portugal is not an isolated legal procedure, but a check of the entire project architecture to ensure compliance with CMVM requirements. The format, the composition of assets, the investor structure, the mechanics of valuation and calculations - everything must be justified in advance. Each element has tax implications, activity restrictions and disclosure requirements. The final configuration does not allow for improvisation: the accuracy of the model and the quality of the preparation will determine whether the fund is approved and can go to market in the right timeframe.