Estate agents in Portugal for Americans (2026): how buying and selling differs for US citizens

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Portugal Owners: free agent matching

Portugal Owners is an independent English-language guide, not an estate agency. Contacting one agency gets you one opinion, and an agency pitching for your listing has a reason to quote high. Tell us about the property once and we ask two or three agencies from this list that suit it for a price estimate, so you compare like with like. Buyers get the agencies and buyer’s agents that hold the kind of home they want, because Portugal has no shared listings system like the US MLS and each agency mainly shows its own stock. It’s free, no agency pays to be listed, and your details go to no agency until you choose. Tell us about your property.

Tradeoff: we don’t list, value or sell property ourselves, so viewings, pricing and the transaction itself are handled by the agency you choose.

How is a Portuguese estate agent different from a US realtor?

The biggest change: in Portugal the agent on the listing works for the seller, and there is usually no one on your side unless you hire them.

	United States (typical)	Portugal
Shared listings	MLS in most markets	No nationwide MLS; listings sit with agencies and on property portals
Who the listing agent represents	The seller	The seller, under a mediation contract (contrato de mediação imobiliária)
Buyer representation	Buyer’s agent is common	Optional; you hire a buyer’s agent and agree the fee in writing
Who pays commission	Negotiated between the parties	The seller, commonly about 5% plus 23% VAT, negotiable
Being paid by both sides	Dual agency allowed in some states	Barred: an agency cannot be paid by buyer and seller in the same deal (Lei 15/2013, article 17(2)(a))
Licence	State real estate licence	Company licence (AMI) from IMPIC, the construction and real estate regulator; check it on IMPIC’s register
Title checks	Title company and title insurance	Your lawyer checks the land registry certificate (certidão permanente) and the tax record (caderneta predial)
Binding stage	Purchase contract, then escrow	Promissory contract (CPCV) with a deposit (sinal), commonly 10–30%; the buyer loses it on walking away, and a seller who backs out usually repays double (Civil Code, article 442)
Closing	Escrow closing	Deed (escritura) at a notary, lawyer or the state Casa Pronta desk

Because the listing agent is paid by the seller, ask any agent who shows you a home: who is paying you on this deal? Our guide to buyer’s agents in Portugal covers fees and conflicts of interest.

What does buying cost an American?

Since 25 May 2026, buyers who are not tax resident in Portugal pay a flat 7.5% IMT on the whole price of a home (Decree-Law 97/2026). Residents pay a sliding scale. Everyone pays 0.8% stamp duty on the price and 0.6% on any mortgage. Casa Pronta charges €375 for the deed and registration without a mortgage, €700 with one.

Worked example: a €600,000 flat in Cascais, cash purchase (figures as on our Cascais buying page).

	American non-resident	Resident, main home
IMT	7.5% × €600,000 = €45,000	8% × €600,000 − €13,763.35 = €34,237
Stamp duty 0.8%	€4,800	€4,800
Casa Pronta	€375	€375
Total	€50,175	€39,412

The non-resident pays €10,763 more. Three exceptions: an American who becomes Portuguese tax resident within two years (for example on a residence visa), or lets the home at a moderate rent, can reclaim the difference by applying within 6 months of qualifying; anyone who was Portuguese tax resident before pays the normal scale; and above €1,150,853 residents pay 7.5% too, so the gap disappears. Run your own figures in the buying cost calculator.

Can a US citizen open a Portuguese bank account?

Yes, but expect FATCA paperwork. Portugal signed a Model 1 FATCA agreement with the United States on 6 August 2015, so Portuguese banks identify US persons and report their accounts to the Portuguese tax authority, which passes the data to the IRS. Banks normally ask US citizens for a Form W-9 with their Social Security number.

You will also need a Portuguese tax number (NIF). As a non-EU owner you must either appoint a fiscal representative or sign up to the Portal das Finanças electronic notifications service, which removes the need for one (General Tax Law, article 19).

What must I report to the IRS while I own it?

Item	Rule
FBAR (FinCEN Form 114)	If your foreign accounts together exceed $10,000 at any time in the year. Due 15 April, automatic extension to 15 October
Form 8938 (FATCA)	Living in the US: over $50,000 at year-end or $75,000 at any time (single); $100,000 / $150,000 (joint). Living abroad: $200,000 / $300,000 (single), $400,000 / $600,000 (joint)
The property itself	Foreign real estate held directly is not reportable on either form
Rent	Reported on your US return; Portuguese tax on it can be credited

A Portuguese account holding the purchase money for a few weeks is enough to trigger the FBAR.

How do you move dollars to Portugal?

• Currency risk runs from CPCV to deed. You fix a euro price months before you pay the balance. A move in the dollar changes your cost in dollars.
• Source of funds. Portuguese banks and the professionals handling the deed must run anti-money-laundering checks (Lei 83/2017). Keep US bank statements that trace the money.
• Compare the all-in rate. The spread on a large transfer matters more than the fee. We do not recommend providers.

Can Americans get a Portuguese mortgage?

Some Portuguese banks lend to non-residents. Since 1 August 2026, Banco de Portugal’s Recommendation 1/2026 caps loans at 90% of value for your own permanent home and 80% for any other purpose, which covers most holiday homes, and caps repayments at 45% of net income (down from 50%). Banks assess income paid in dollars against the same limits.

A euro mortgage creates a US tax point. When you repay it, a stronger dollar can produce a taxable currency gain, while a currency loss on a personal home loan is generally not deductible (26 U.S. Code § 988 and IRS rulings). Ask a US preparer before choosing between a euro and a dollar loan.

What happens when an American sells?

Portugal taxes first. Non-residents pay tax on 50% of the gain at progressive rates of 12.5% to 48%, with the rate set by worldwide income; the old flat 28% rate ended on 1 January 2023. No tax is withheld at the deed. The gain goes on the Portuguese return between 1 April and 30 June of the following year. See capital gains tax for non-residents.

The US taxes US citizens on worldwide gains. Under the 1994 US–Portugal treaty, Portugal may tax gains on Portuguese real estate (article 14), and the US gives a credit for Portuguese income tax (article 25). A “saving clause” lets the US tax its citizens as if the treaty did not exist, so the treaty does not exempt you.

Four US rules change the result:

• Dollars, not euros. Convert the purchase price at the exchange rate when you bought and the sale price at the rate when you sold. The US gain can be higher or lower than the euro gain.
• Section 121. If the home was your main home for 2 of the last 5 years, you can exclude up to $250,000 of gain ($500,000 on a joint return). Publication 523 sets no requirement that the home be in the US.
• Foreign tax credit (Form 1116), capped at the US tax on the same gain.
• Net Investment Income Tax. The IRS does not allow foreign tax credits against the 3.8% NIIT. Ask your preparer whether it applies to you.

Worked example: a Lisbon flat bought in 2018 and sold in 2026

A married American couple living in the US bought for €400,000 in 2018, paid €30,000 of purchase taxes and costs, and sell in 2026 for €600,000 with 5% commission plus VAT. Their other income is about €80,000. Exchange rates are illustrative: $1.18 per euro at purchase, $1.10 at sale. The Portuguese inflation coefficient for 2018 is 1.17 (2025 table).

Portugal	Calculation	€
Sale price		600,000
Purchase price adjusted	400,000 × 1.17	−468,000
Purchase costs		−30,000
Commission	600,000 × 5% × 1.23	−36,900
Energy certificate		−200
Gain		64,900
Taxable (50%)		32,450
Rate set on	32,450 + 80,000	112,450
Average rate (2026 table)	42,588.73 ÷ 112,450	37.87%
Portuguese tax	32,450 × 37.87%	≈ 12,290

United States	Calculation	$
Amount realised	(600,000 − 36,900 − 200) × 1.10	619,190
Basis	(400,000 + 30,000) × 1.18	−507,400
Gain		111,790
Tax at 15% long-term rate		16,769
Foreign tax credit	€12,290 × 1.10	−13,519
Remaining US tax		≈ 3,250

Portugal’s 50% inclusion and inflation coefficient make its tax lower here, so a US balance remains. The couple’s income stays under the $250,000 NIIT threshold for joint filers. Model the Portuguese side in the selling calculator.

Agencies that serve English-speaking and American clients

These firms are already on our area lists, each with its AMI licence checked on IMPIC on 24 September 2026. We include only firms that state they work in English or, in one case, give a US contact number. They are listed alphabetically, not ranked, and none paid to appear.

Firm	Type	What it states	AMI	Full profile
Brint	Buyer’s agent	English website, US phone number (+1 888); no Portuguese office address found	19563	Cascais
Engel & Völkers Cascais	Network shop	Six languages, including English	18136	Cascais
Engel & Völkers Lisbon	Network shop	English, Portuguese, Spanish	15208	Lisbon
Goldcrest	Buyer’s agent	English and Portuguese website	23310	Lisbon buyer’s agents
Inside Living	Independent, Cascais	Eight languages, including English	8417	Cascais
Lisbon Buyer’s Agent	Buyer’s agent	Works in English, mostly online; publishes fees	13600	Lisbon buyer’s agents
RE/MAX Collection Valor	Network franchise	English, Portuguese, Spanish, French; “free and personalised service for buyers”	6275	Lisbon

Brands Americans know, such as Keller Williams, RE/MAX, Century 21, Sotheby’s International Realty and Christie’s International Real Estate, operate in Lisbon or Cascais through separate Portuguese licensed companies. A US agent under the same brand does not represent you in Portugal, and your contract is with the Portuguese company that signs it. More areas are on our estate agents in Portugal page.

What paperwork does an American buyer need, in Portugal and the US?

Two Portuguese steps before and after you buy, and up to two US forms for each year you hold money in a Portuguese account.

Step	The rule	Where it comes from
Portuguese tax number (NIF)	Needed before you open a bank account or sign the CPCV. It is free. See how to get a NIF	Portal das Finanças
Fiscal representative	Once you own property and live outside the EU/EEA, you have 15 days to appoint one or sign up for electronic notifications on the Portal das Finanças. The notifications option has existed since 9 July 2022. The fine for doing neither is €75 to €7,500	General Tax Law, article 19, as amended by Decree-Law 44/2022; RGIT, article 124
FBAR (FinCEN Form 114)	Filed online with FinCEN through the BSA E-Filing System, not with your tax return. The highest balance is converted at the Treasury exchange rate for the last day of the year	IRS and FinCEN
Form 8938	Filed with your Form 1040 if you pass the thresholds. The penalty for not filing is up to $10,000, plus $10,000 for each 30 days after an IRS notice, up to $60,000 in total	IRS
Home held through a Portuguese company	Held in your own name, the home is not reported on either form. Held through a company, the company counts as a foreign financial asset on Form 8938, and its value includes the home	IRS
Moving to Portugal	The D7 visa needs regular income of at least €920 a month in 2026 (€1,380 for a couple). See the D7 visa	Decreto-Lei 139/2025; Portaria 1563/2007

Worked example: a married couple filing jointly moves €300,000 into a Portuguese account to pay the deposit and the balance. At an illustrative $1.10 per euro, that is $330,000.

	Living in the US	Living abroad (as the IRS defines it)
FBAR: over $10,000 at any time	Required	Required
Form 8938, joint thresholds	$100,000 at year end or $150,000 at any time	$400,000 at year end or $600,000 at any time
Form 8938 for this couple	Required: $330,000 is over $150,000	Not required: $330,000 is under both limits

The dollar figure uses the exchange rate on 31 December, not on the day you sent the money, so a move in the dollar can change the result.

Frequently asked questions

Do I have to report my Portuguese house to the IRS?

Not on the FBAR or Form 8938, if you own it in your own name. The Portuguese bank accounts you use to buy and run it are reportable. Rent and any gain on sale go on your US return. If you own the home through a Portuguese company, the company goes on Form 8938.

Do I file the FBAR with my tax return?

No. The FBAR goes to FinCEN, online through the BSA E-Filing System, separately from your return. It is due on 15 April, with an automatic extension to 15 October. Form 8938, by contrast, is attached to your Form 1040.

Can an American get residency by buying property in Portugal?

No. The Golden Visa route through buying property ended in October 2023 (Lei 56/2023). Americans who want to live in Portugal usually apply for the D7, which needs income of at least €920 a month in 2026. Becoming Portuguese tax resident within two years of the purchase lets you claim back the extra IMT you paid as a non-resident.

Does an American owner need a fiscal representative in Portugal?

Not if you sign up for electronic notifications on the Portal das Finanças. That option has existed since 9 July 2022 (Decree-Law 44/2022). Otherwise, once you own property and live outside the EU/EEA, you must appoint a representative within 15 days.

Key points

• The listing agent works for, and is paid by, the seller; hire a buyer’s agent if you want representation, and get the fee in writing.
• Non-residents pay 7.5% IMT since 25 May 2026: €50,175 in taxes and deed costs on a €600,000 flat, against €39,412 for a resident. The gap is reclaimable if you become resident within two years.
• Portuguese banks report US account holders under FATCA; file an FBAR once your foreign accounts pass $10,000.
• From 1 August 2026, Portuguese mortgages for non-main homes are capped at 80% of value, and repayments at 45% of income.
• On a sale, Portugal taxes 50% of the gain; the US taxes the full dollar gain and credits Portuguese tax, and Section 121 can apply to a main home abroad.
• Check every agency’s AMI licence on IMPIC before you sign anything.