Every week this publication records new traffic on the Portugal–Nordic corridor: Portuguese groups buying Swedish dealerships and pet-store chains, Swedish and Finnish industrials expanding Portuguese plants, service teams invoicing across four borders. Almost none of that coverage mentions the corridor’s strangest structural fact: two of the four Nordic countries — Finland and Sweden — have no double-taxation treaty with Portugal at all. Finland has been treaty-less since 1 January 2019, Sweden since 1 January 2022. Among EU member-state pairs, a missing tax treaty is a genuine rarity — and here it applies twice on a single trade corridor.
The story of how it happened is well documented. Portugal’s non-habitual resident (NHR) regime, introduced in 2009, allowed foreign pensioners who relocated to Portugal to receive private-sector pensions effectively tax-free — untaxed in Portugal under NHR, and untaxed at source because the old treaties assigned taxing rights to the country of residence. Helsinki and Stockholm objected, renegotiated, and signed replacement instruments — Finland a new treaty in 2016, Sweden a protocol in Brussels in May 2019. Portugal’s parliament ratified neither. Finland ran out of patience first, terminating its 1970 treaty with effect from 2019; Sweden’s Riksdag voted on 2 June 2021 to terminate its convention, effective 1 January 2022 — the first time in modern practice Sweden had walked away from a tax treaty with a fellow EU state.
The irony: the cause is gone, the gap remains
What makes the situation remarkable in 2026 is that the dispute that caused it has largely been resolved. Portugal closed the NHR regime to new applicants from 2024; its successor framework for incoming skilled professionals (IFICI, often called “NHR 2.0”) pointedly excludes pension income. Sweden, meanwhile, now taxes Swedish-source pensions paid to residents of Portugal — typically under the 25 percent SINK regime for non-residents. The zero-tax pensioner, the original casus belli, has effectively ceased to exist. Yet no new treaty has been signed with either country, and the friction has migrated from retirees to the businesses this corridor is actually made of.
What the gap actually costs
Goods trade — wine into the monopolies, cork, textiles, machinery — is largely unaffected, since customs duties and VAT do not depend on income-tax treaties. The pain concentrates in services, capital flows and people. Without a treaty, Portugal applies its domestic withholding tax — generally 25 percent — on many service fees and royalties paid to Swedish or Finnish providers, a cost treaties would normally reduce or eliminate; Swedish advisory firms have been warning clients about Portuguese withholding on service invoices since the treaty lapsed. In the other direction, Sweden’s domestic dividend withholding for foreign shareholders runs at 30 percent absent treaty relief. EU instruments blunt part of this — the Parent-Subsidiary and Interest-Royalties Directives protect qualifying intra-group flows, and both countries offer unilateral credit mechanisms — but directive relief is narrower than treaty relief, and individuals, minority shareholders and smaller service providers frequently fall outside it.
Just as consequential is what disappears with a treaty’s machinery: no mutual agreement procedure to resolve double-taxation disputes, no treaty-based arbitration for transfer-pricing conflicts, and less certainty on questions like permanent establishment — precisely the questions a Portuguese scale-up hiring its first Stockholm employees, or a Finnish group seconding engineers to a Portuguese plant, needs answered. Tax advisers on both sides can usually engineer around the gap; the point is that corridor businesses pay for that engineering while their competitors working, say, the Portugal–Spain or Sweden–Denmark routes do not.
A corridor that has outgrown its plumbing
The gap persists even as both relationships boom. Sweden’s embassy in Lisbon counts some 260 Swedish companies in Portugal, contributing an estimated €4.2 billion to the Portuguese economy over the past five years, and surveys of the Luso-Swedish business community show a large majority planning to invest more. Finland’s corporate presence — Nokia’s roughly 2,800-person Amadora operation, ICEYE’s new Lisbon subsidiary, Metso, Kempower, Aiven and dozens more — has never been larger. Traffic northward is growing just as fast: Salvador Caetano became sole owner of Sweden’s Hedin Caetano distribution business on June 30, Sonae runs its Nordic pet-care platform through Helsinki-listed Musti, and Portuguese software, construction and wine businesses invoice Nordic clients daily. Every one of those relationships crosses at least one treaty-less border.
There is political movement, but it is slow. In Sweden’s Riksdag, opposition members have repeatedly pressed the government to reopen negotiations — an interpellation in late 2023 and a fresh motion in the 2024/25 session both called for a new treaty — and Finance Minister Elisabeth Svantesson has said Sweden is open to a new agreement “if the conditions are right.” Lisbon, having dismantled the pension exemption that started the fight, has an obvious interest in restoring investor certainty. As of mid-2026, however, no new Swedish or Finnish treaty with Portugal has been signed, and none is publicly scheduled for signature.
Why this matters for the corridor. Norway and Denmark retain functioning treaties with Portugal — a quiet competitive advantage for Oslo- and Copenhagen-based groups over their Swedish and Finnish peers, and worth checking before structuring any corridor investment. For companies planning either direction, the treaty gap belongs on the first page of the market-entry checklist, not the last. This article is journalism, not tax advice; the specifics turn on individual circumstances and professional counsel.