Serving expat and cross-border buyers in Portugal

Buyers in Portugal increasingly live in one country, hold the passport of another and move money from a third. This briefing sets out what an agency has to establish about such a buyer and why the order matters. In Portugal the order is shaped by the tax number, by the anti-money-laundering rules that apply to estate agents and by a transfer tax that depends on tax residence.

Record citizenship and tax residence separately

Write both down at the first contact. Citizenship tells you whether the buyer is an EU citizen, which affects the tax number procedure. Tax residence tells you which transfer tax rate may apply. Since 2026, reports say a flat rate of 7.5 percent of IMT applies to buyers who are not tax residents in Portugal, with exceptions when the buyer is already resident or becomes resident within two years. So a buyer's plan to move to Portugal, and its timing, is a fact about the price of the property, not a private detail. Ask for it and record the answer. See our briefing on 2026 changes.

The Portuguese tax number (NIF)

A NIF is needed for the purchase. Guides state that both residents and non-residents can obtain one and that most banks require it. They also say that a non-EU resident needs a fiscal representative, a Portuguese resident individual or company who acts as the contact with the tax authority, and that without one the application is not accepted; EU residents are reported not to need a representative. Confirm the current rule with your lawyer or the tax authority. Start this step early, because the NIF is also needed to open a bank account, to sign the deed and to register ownership.

Identity, address and funds

For a natural person, collect and verify:

• A valid passport or, for EU citizens, an ID card or residence card, with certified copies.
• Proof of address in the country of residence and the country of tax residence.
• The NIF, or a plan and a representative for obtaining it.
• For a company buyer, its documents and the identity of every beneficial owner.
• Source of funds and wealth, with documents: salary or tax records, a sale contract for another property, a company extract, an inheritance document or a loan agreement.

Guides advise buyers to expect anti-money-laundering questions and to have proof of identity, address and source of funds ready. They also say a buyer can usually complete without a Portuguese bank account, because completion funds commonly move through the lawyer's client account, but many buyers open one for the NIF, the utilities and the tax bills.

What the law asks of the agent

Estate agency, buying and selling real estate for resale, property development and leasing are covered by the national anti-money-laundering law (Law 83/2017), and the sector regulator IMPIC sets out how the duties apply in its Regulation 276/2019. As summarised by law firms, identification and due diligence must be carried out before a transaction involving a promissory contract is concluded, the agent must have internal policies and procedures, and the agent must communicate transactions and certain high-rent leases to IMPIC at set intervals. The reported rental threshold is EUR 2,500 per month and the reporting is quarterly. Thresholds and forms change, so check the regulator's current instructions.

For an agency that has served mostly local buyers, the change is practical: a written client file, a named compliance contact and a repeatable checklist.

Sanctions screening and difficult profiles

Screen the buyer, the payer and the beneficial owners against the EU consolidated financial sanctions list before you accept instructions and again before the deed. Funds and economic resources of a listed person are frozen and real estate may not be sold to or on behalf of a listed party, and an entity can be caught through ownership or control by a listed person.

Buyers from Russia or Belarus, or with ties to them, may meet extra bank questions. EU rules limit the deposits that EU banks may accept from Russian and Belarusian nationals and residents above EUR 100,000, and exemptions exist. Read the European Commission's FAQ and ask the buyer to confirm with their bank. Never help anyone avoid a check or split or reroute a payment.

Cash

Portuguese law restricts cash payments. As reported, the general limit is EUR 3,000 for payments by or to residents and a higher limit of EUR 10,000 for individuals who are not resident and are not acting as traders, with fines for breaches. For a property purchase the money should move by traceable means, such as a bank transfer or a nominative cheque. Do not accept or arrange cash for any part of the price.

Checklist

• Citizenship, tax residence and the plan to become resident.
• NIF and, where needed, a fiscal representative.
• ID, address proof and source of funds with documents.
• Sanctions screening with the date.
• Traceable payment plan and no cash.
• A lawyer to check the registry extract, the tax record of the property and the habitation licence.

Working with D.H. Realting

D.H. Realting is a trilingual (Russian, English, Polish) overseas-property platform. We introduce buyers, including expats living in Poland, the EU and elsewhere, to properties abroad, and we support the process on the buyer's side. Agencies and developers in Portugal that handle the deal locally and would like to be introduced to such buyers can contact us through our partners page.

This briefing is informational only and is not legal, tax or investment advice. Rules change and apply case by case, so confirm every point with a qualified local lawyer before acting. Last checked on 11 October 2026.