Nikita Veremeev
07.02.2026 | 6 min read
Updated: 07.02.2026
I have been building COREDO since 2016 and have set up dozens of structures in the EU, the UK, Singapore, Dubai and Central Europe through incorporation, licensing and tax planning. In recent years Portugal has become a notable hub of European crypto business. The COREDO team has implemented a number of projects to create crypto holdings in Lisbon and Porto, and by 2026 the picture has become significantly more mature: MiCA comes fully into force, DAC8 and CARF change the rules of information exchange, and the Portuguese tax regime (IRC) is finally adapting to crypto assets.
In this article I have compiled a practical roadmap: how to choose a legal form, meet substance requirements, obtain CASP registration, set up AML/KYC and accounting under IFRS, plan profit repatriation and withstand tax audits. I rely on specific COREDO cases and break down the key issues: taxes on crypto assets in Portugal, corporate tax (IRC) for Portuguese crypto companies, transfer pricing, Pillar Two and the implications of MiCA/DAC8/CARF.
Portugal’s regulatory landscape 2026
By 2026, the Portuguese ecosystem looks structured. Autoridade Tributária (the Portuguese Tax Authority, AT) issues guidance on crypto operations and monitors declarations. Banco de Portugal oversees the registration of crypto-asset service providers (CASPs), including AML requirements/KYC and the Travel Rule. The Portuguese Securities Market Commission (CMVM) supervises security tokens, prospectuses and trading venues for tokenized securities.
MiCA (Markets in Crypto‑Assets Regulation) introduces unified rules in the EU: By 2026, CASPs operate under standards for licensing and operational risk, reserve requirements for stablecoins and risk disclosure. DAC8 expands the automatic exchange of information on crypto-assets, while the OECD CARF sets a global reporting framework. COREDO’s practice confirms: the “do the minimum and hide” strategy no longer works. Build compliance from the start “for audit” — it saves years, not months.
Private limited company vs public limited company and tax residency
The following are most suitable for holdings and operating crypto companies in Portugal:
- Sociedade por Quotas (Lda) – equivalent of a private limited company, flexible management structure, moderate capital requirements.
- Sociedade Anónima (SA): a form for large structures and public plans, stricter corporate procedures and a board of directors.
When I create a crypto holding in Portugal I start by assessing the group’s prospective structure and investors’ requirements. If a client is preparing for a listing or a Security Token Offering under CMVM supervision, an SA removes a number of barriers in advance. For a family-office holding or a fund, an Lda is more economical to administer. A company’s tax residency in Portugal is determined by its place of effective management: the board of directors, the making of key decisions, local directors and office — the elements on which the AT places emphasis.
substance of a crypto-holding in Portugal
Economic justification of substance — not about a “paper” office, but about real activity. I set out the minimum:
- a resident director with fintech/crypto experience and a real management role;
- a physical office where meetings are held and originals of documents are kept;
- local functions: risk management, an AML officer, accounting, preparation of financial reports;
- contracts with local providers (custody, audit, legal support), reflecting the ‘centre of interests’ in Portugal.
The economic justification of substance pays off twice. Banks open accounts faster, and tax rulings are resolved predictably. A solution developed at COREDO for one crypto group with assets in the EU and Asia reduced banking KYC friction fourfold by transferring the risk function and data governance to Lisbon.
IRC for crypto holdings
Crypto-holding Portugal taxes are about IRC and related regimes. The basic IRC rate: 21% on the mainland, to which a municipal surcharge of up to 1.5% and a state surtax on large profits applied progressively are added. For small and medium enterprises a reduced rate applies to the “first tier” of profits. Details change with budgets, but the Effective Tax Rate is usually 22–26%, which is above the Pillar Two threshold.
The conditions for applying the participation exemption in Portugal allow dividends and capital gains on shareholdings to be exempt from tax when the criteria are met: generally a shareholding of at least 10%, a holding period of at least 12 months, taxation of the investee by a comparable corporate tax and absence from a “blacklist”. For a crypto-holding this is the key to tax-optimizing repatriation of funds from subsidiaries in the EU and certain third countries.
Profit repatriation and withholding taxes in Portugal depend on bilateral double tax treaties (DTT) and EU directives. Standard WHT rates in Portugal are 25% on dividends, interest and royalties, but DTTs and the Parent-Subsidiary Directive reduce or eliminate them when conditions are met. The COREDO team implemented a cascaded structuring of payments using the participation exemption and DTTs, reducing aggregate withholding to zero without aggressive schemes.
Taxes on crypto-assets in Portugal
AT in 2026 bases its approach on the functional nature of the transaction. For companies, income and losses from crypto-assets form part of the IRC taxable base. The classification of tokens for tax purposes in Portugal is based on their economics:
- utility tokens, a right of access to a service, accounted for as an intangible asset or a prepayment;
- security tokens – characteristics of a security, supervision by the CMVM, potential application of rules for financial instruments;
- asset-backed, asset tokenization, a distinct legal and fiscal profile.
The tax consequences of staking, mining and airdrops differ. Staking is often recognized as operational income as rewards are accrued; mining – entrepreneurial activity taxable under IRC taking into account expenses (electricity, equipment); airdrops and hard forks are taxable events at fair value on the date of receipt with subsequent recognition of gain/loss on disposal. Labeling transactions as: disposals, acquisitions, swaps – allows correctly separating capital gains vs operational income.
Taxes on token exchanges and token-swaps in a corporate environment arise both on sale and on exchange of one asset for another if beneficial ownership or the economic substance of the asset changes. For illiquid tokens I apply conservative valuation models: DCF (if there are cash flows), market comparables from transactions, or last round for tokens related to equity. AT readily accepts documented methodologies; COREDO’s practice shows that a transparent model and independent valuation reports materially reduce the risk of dispute.
VAT on trading crypto assets and NFTs
VAT and cryptocurrency trading: Portuguese rules follow the EU Hedqvist case, fiat/crypto exchange is exempt from VAT as a payment transaction. But not all crypto services fall under the exemption. Custodial services, technical support, SaaS access to protocols, market-making and listing packages are usually subject to 23% VAT in mainland Portugal.
Taxation of transactions with NFTs and tokenized assets depends on their substance. The sale of a digital work of art is an electronic service subject to VAT at the place of consumption (rules for B2C digital services); tokenization of rights to a real asset carries the VAT/stamp implications of the underlying asset and may require registration in the country where the asset is located. VAT refunds and indirect tax relief on the provision of crypto services are possible with correct determination of the place of supply and by keeping separate accounting of input VAT.
CASP Registration: AML/KYC Requirements
The definition of VASP/CASP and registration requirements by 2026 are established by MiCA and local law. Banco de Portugal registers conversion providers, exchangers, custodians, issuers, platform operators.
AML/KYC requirements for crypto holdings and CASPs include:
- AML‑Risk Assessment, written policies and procedures;
- KYC/KYB, PEP‑screening and enhanced Due Diligence for investors;
- Blockchain‑analytics and AML tools (on‑chain monitoring), Travel Rule;
- financial monitoring and sanctions compliance (FATF Guidance on virtual assets and VASP).
The cost of AML/CTF compliance and a holding’s operational expenses are not a penalty but insurance. In one project COREDO implemented a cascading verification model: auto‑scoring + manual EDD for high risks, integrations with on‑chain monitoring providers and centralized case management. False positives decreased by 37%, and onboarding time was reduced from 12 to 5 days, with total savings of more than 200 person‑hours per month.
UBO Beneficiary Register and Privacy
The UBO register (Registo de Titular Beneficiário) in Portugal is mandatory for all companies. Investor confidentiality and the implications of CARF for UBOs require careful structuring: nominee holders do not solve the problem. I recommend aligning disclosures with the group’s legal strategy, conducting a DPIA under the GDPR for CARF/DAC8 data flows, and drafting contractual provisions with custodian/exchange providers on the division of controller/processor roles.
MiCA, DAC8, CARF: crypto business models
The impact of MiCA and DAC8 on the business models of crypto holdings is expressed in three ways. Firstly, Licensing of CASP and capital/risk management requirements raise the entry barrier but provide a “passport” to the EU market. Secondly, the expansion of reporting under DAC8/CARF makes anonymous schemes expensive and risky. Thirdly, B2B clients demand transparency of the transaction chain and on-chain reports as the standard.
OECD CARF and the automatic exchange of information on crypto transactions are not just about retail. Institutional providers are subject to reporting obligations, and the group must build master data: a single client identifier, beneficiary registers, transaction metadata. Our experience at COREDO has shown: if you design data governance from the start for CARF/DAC8, auditors close issues faster, and AT asks for clarifications less often.
Impact of GloBE on crypto structures
Pillar Two / GloBE rules and the calculation of the effective tax rate are important for groups with revenue ≥ 750 million. Portuguese companies most often report an ETR above 15%, but local incentives and tax credits can shift the calculation. For a holding company, a GloBE “dry run” is useful: detail timing differences, verify the qualification of tax credits, and ensure that participation in reduced-tax regimes will not lead to a top-up in another jurisdiction.
BEPS 2.0 strengthens requirements for economic presence (economic substance) and transparency. I take this into account in the design of holdings: a genuine asset-management function in Portugal and documented processes reduce the risk of adjustments in source jurisdictions.
Transfer pricing for tokens
Transfer pricing: the CUP, TNMM and cost plus methods for token transactions are applicable in the same way as for traditional assets. For intercompany transfers of tokens with market quotations the CUP method most often works (arm’s length at the market price with adjustments for liquidity and lock‑ups). For protocol development and market‑making operations – cost plus or TNMM with margin benchmarking.
Transfer pricing documentation for crypto groups in Portugal is mandatory upon reaching revenue and intercompany turnover thresholds. I prepare the master file and local file, a token valuation policy, a functions/risks/assets analysis, as well as procedures for unpriced events (airdrops, hard forks). Advance Pricing Agreement (APA) and pre‑ruling decisions remove uncertainty; tax resolutions (binding rulings) in Portuguese practice are issued within reasonable timeframes when filed properly.
Accounting for crypto-assets under IFRS and in Portugal
Accounting for crypto-assets under IFRS and Portuguese accounting standards in 2026 follows the approach: crypto-assets: intangible assets (IAS 38), except where traders hold them as inventory at fair value. Impairment, impairment tests and disclosures are mandatory, and the valuation policy is subject to audit. The IFRS project on crypto assets is moving toward clarifying classification and disclosures, and auditors are scrutinizing accounting policies.
Valuation policies and accounting policies for tokens in the annual report must record the choice of mark‑to‑market vs cost basis, sources of prices, and the liquidity hierarchy. Cold wallet vs custodial wallets carry different operational and tax consequences: custodial fees (custody fees) may be charged to expenses, while cold‑storage requires internal access controls and SOX-like procedures for public groups. Internal controls and key management are among the first topics in any due diligence.
Declaration, audits and disputes by 2026
The procedure for declaring cryptocurrencies in the Portuguese tax return is set out in AT instructions: report income/losses, disclose valuation methodologies, and provide notes on non-standard transactions. Tax inspections and audits of a crypto-holding in 2026 focus on three triggers: mismatch between on‑chain movements and accounting, lack of TP documentation for intercompany token transfers, and weak AML procedures.
How to prepare for a tax audit of a crypto-holding in 2026? Maintain reconciliations on‑chain/off‑chain, independent valuation reports, board minutes on key decisions, and reports from the AML officer. Legal support and obtaining tax rulings for the holding help stabilize positions before a dispute begins. The COREDO team successfully closed AT claims on the classification of staking income by providing correspondence with the regulator and justification for income recognition under the accrual method.
Dividends and WHT: profit repatriation
Withholding tax (WHT) on dividends, interest and royalty payments in Portugal is standardly 25%, but bilateral treaties (DTT) allow lowering the rates. Double taxation treaties: Portugal’s WHT rates often fall to 5–15% on dividends and 10% on interest/royalties, and in the EU zero is possible if directive requirements are met. Dividend repatriation and the tax optimization of repatriating funds from a crypto-holding are built around participation exemption and a managed payout schedule.
Re-investment of profits and tax consequences should be aligned with the business cycle: losses on tokens can be carried forward (tax loss carryforward) with a restriction on the share of profits, and R&D credits and tax benefits and incentives for investment holdings in Portugal reduce the burden when developing technologies. I set KPIs: ROI metrics taking into account tax efficiency and compliance costs, so the board sees the full picture, not only the “nominal” rate, but also the cost of compliance.
International structures, family offices
International structures: a branch or a subsidiary for crypto operations, the question of control and taxation at source. A branch is easier to set up, but its profit will be taxed directly in Portugal; a subsidiary is more convenient for participation exemption and managed WHT on dividends. Using a Portuguese holding structure for funds and a family office provides predictability, access to DTT and a clear regime for asset management.
Cross-border transfers of tokens do not fall under customs in the classical sense, but they trigger currency and sanctions compliance, and sometimes local licensing rules. Cross-border payments and banking compliance in Portugal are standardized, but banks require proven substance and transparent sources of funds. Repatriation of capital should be accompanied by banking AML checks and pre-prepared dossiers on counterparties.
DeFi: derivatives and custodial services
Taxation of income from DeFi, yield farming and liquidity aggregation depends on the legal qualification of the contract: rewards – operating income, while derivatives: financial instruments with separate accounting for fair value. In the corporate environment, record the protocol terms, counterparty risk and the PnL valuation methodology. Crypto custody and the tax regime for custodial services in Portugal imply VAT taxation of the service and IRC on the margin.
Security token exchange and CMVM regulation set the framework for STO/listings. ICO/STO and the tax treatment of fees and income require separate accounting: what is a prepayment for a service, what is a debt obligation, what is equity. The COREDO team structured the STO of an infrastructure project under CMVM supervision, agreeing the prospectus and the accounting model for amortization of token liabilities; the investor-side audit passed without remarks.
Governance / responsibility / due diligence
Corporate governance (CG) practices for international crypto holdings include independent directors, a risk and audit committee, SOX‑like requirements for public holdings, and key‑control tests. Liability of directors and executives for tax non‑compliance is real: AT and CMVM expect personal involvement, minutes of meetings, and approval of policies.
Situational due diligence when acquiring a crypto holding checks three areas: tax (IRC, VAT, WHT, TP‑documentation), regulatory (CASP, AML/KYC, CMVM licenses, Banco de Portugal), finance (IFRS, impairment tests, valuation reserves). The role of the tax adviser and the lawyer in structuring the holding is to synchronize these tracks and secure timely binding rulings.
Risks of double taxation and CbCR
Risks of double taxation in cross‑border operations with cryptoassets arise when countries classify transactions differently. Double taxation: exemption, credit, DTT consultations – the standard toolkit, but crypto adds a layer of valuations and events. Country‑by‑Country Reporting (CbCR) for multinational groups requires an agreed allocation of profits and personnel, and crypto functions (protocol development, liquidity management, AML functions) should be reflected where they actually occur.
COREDO cases – what works
- European crypto exchange and custody. The COREDO team obtained CASP registration with Banco de Portugal, implemented an AML framework with on-chain analytics and obtained an APA on intra-group market-making commissions under TNMM. Result: predictable tax burden and fast bank onboarding for large clients.
- Family office with tokenized assets. The solution developed at COREDO used Lda as a holding, the participation exemption for dividends from the EU and DTT for royalties. We obtained a binding ruling classifying NFT income as electronic services, established VAT accounting and secured a refund of input VAT on development.
- DeFi liquidity provider. Our experience at COREDO showed that a documented methodology for valuing remuneration and a compact master file for TP smooth out the rough edges in audits. AT accepted a cost-plus model for service functions and CUP for intra-group liquidity transfers with a discount for locking.
How to set up a crypto holding in Portugal
- Choice of form (Lda vs SA) and group design under participation exemption and DTT.
- Confirmation of tax residency: directors, office, board meeting calendar.
- Registration of CASP (if necessary), appointment of an AML officer, implementation of KYC/KYB, PEP screening, Travel Rule and on-chain monitoring.
- UBO registry, GDPR‑DPIA and data‑governance policies under DAC8/CARF.
- Accounting policy: IFRS, token valuation (mark‑to‑market or cost), impairment tests, key control.
- TP policies: CUP/TNMM/cost plus for token transactions, master/local file, where possible: APA.
- VAT model: exemptions, electronic services, place of supply, refund of input VAT.
- Banking compliance: counterparty dossiers, description of flows, confirmation of substance.
- Audit plan and AT checks: on‑chain/off‑chain registers, AML reports, board minutes.
- ROI model: tax rate, cost of compliance (KYC/AML, reporting, audits), repatriation and re‑investment scenarios.
Scaling and Exit Strategies
Strategies for scaling the crypto‑business that take tax burden into account rely on diversification of functions within the EU, expansion of the CASP‑license and integration with institutional custody providers. Exit strategies: M&A, asset sale, IPO and tax consequences require early planning, TP‑history, clean IFRS reporting and the absence of “skeletons” in the AML closet increase the deal multiple.
The tax consequences of tokenising assets on the holding’s balance sheet and of custody models need to be recorded in prospectuses and contracts. CMVM closely examines the economics of token rights, and AT looks at the recognition of income and reserves. I recommend preparing pre‑rating solutions and binding rulings before market entry.
Non-compliance risks: case law
Consequences of non-compliance with VAT and AML rules for a holding – from additional assessments and penalties to administrative and criminal sanctions for tax violations. Tax audits: key triggers for audits of crypto‑operations: discrepancies between DAC8/CARF data and reporting, “gray” staking schemes and the lack of a documented valuation of tokens. legal risks and case law on crypto disputes in Portugal are developing rapidly, and predictability increases for those who have obtained AT rulings in advance and agreed prospectuses with the CMVM.
What is important to remember
Taxation of crypto-holdings in Portugal 2026: it’s a system, not a set of life-hacks. Choose a form (Lda or SA), confirm substance, build CASP compliance and AML frameworks, establish the TP model and accounting policies under IFRS, and then plan repatriation taking into account the participation exemption and DTT. Pillar Two, MiCA, DAC8 and CARF do not hinder business – they require discipline and transparency.
COREDO’s practice confirms: the earlier you embed tax and regulatory architecture into the product and processes, the faster you can scale and the lower your cost of capital. If you are planning to establish a crypto holding in Portugal or are reviewing an existing structure, build three steps into the plan: risk assessment, compliance design and preliminary decisions with regulators. This is one of those cases when strategic preparation creates an advantage measured not in words, but in the figures on the P&L and exit multiples.