Architecture
Corporate Structure & Flows
How money moves inside the group determines how much tax you pay, what risk you carry, and what options you have when an opportunity appears.
Contact us: geral@intuitionconsulting.net
Is it worth creating a holding company in Portugal?
It is worth it when there is more than one company, when profits are not all distributed, when risk needs separating from wealth, or when one of the companies may be sold. The core advantage is the participation exemption regime: where the legal shareholding and holding-period requirements are met, dividends and capital gains received by the holding are not taxed, allowing reinvestment without an intermediate tax cost. For a single company distributing everything, a holding rarely justifies the added complexity.
Who this is for
- Groups with several companies and no parent
- Owners reinvesting profits into new projects or real estate
- Shareholders preparing the future sale of one group company
- Structures with unformalised shareholder loans
Signs you need this
- Distributing dividends feels like paying tax twice
- Each new company is created standalone, without group logic
- Cash sits idle in one company and is missing in another
- Shareholder loans were never formalised
- The current structure makes selling one company expensive
What we deliver
Holding architecture
Parent company design, shareholdings and participation exemption positioning.
Dividend optimization
How to move results up and around the group with the least legally achievable friction.
Intercompany flow design
Shareholder loans, additional contributions, service agreements and transfer pricing.
Participation exemption analysis
Verification of holding thresholds and conditions securing the exemption.
How we work
Review
Current structure, shareholdings, retained earnings and intercompany movements.
Modelling
Scenario comparison with the tax cost of reaching each and the recurring annual effect.
Final design
Target structure, sequence of steps and the regime applicable to each.
Execution
Coordination of lawyers and accountants until the structure is registered and operating.
What changes at the end
Frequently Asked Questions