e-Residency de Estonia vs. visados D2 portugueses: Comparativa de estrategias para nómadas digitales

Last week I received this message: Richard, I am completely confused. Should I apply for e-Residency in Estonia or rather go for the D2 Visa for Portugal? Which is smarter from a tax perspective?

And heres the first big misconception.

These two options are like apples and oranges. Still, theyre constantly compared. I get it—both promise a certain independence from the German tax system at first glance.

But in reality, things are more complex.

As someone who works every day with international entrepreneurs, I see the same misunderstandings over and over again. Thats why today, I want to take you along on an honest analysis of both paths.

You’ll come to understand why e-Residency is not a tax haven, and why the D2 Visa does not automatically reduce your tax burden. But above all, I’ll show you which option is right for your particular situation.

Ready for the unvarnished truth?

The truth about virtual vs. physical residency: What nobody tells you

Before we dive into the details, let me clear up the biggest myth:

Neither e-Residency nor the D2 Visa will automatically solve your tax problems.

That may sound sobering, I know. But this honesty is precisely what separates me from the tax-saving gurus who promise you the world.

What virtual residency really means

e-Residency is a digital gateway to Estonian e-services. That means: You get a digital identity, can found a company and take care of official tasks entirely online. Sounds fantastic, right?

But – and this is crucial – you don’t become an Estonian tax resident through this.

Your tax obligations still depend on your actual place of residence and business activities. If you spend 200 days a year in Germany, you remain a German tax resident. Period.

What physical residency really achieves

The D2 Visa, on the other hand, gives you legal residency in Portugal. You can settle there, work, and after five years even apply for citizenship.

Key point: With the D2 Visa, you can end your German tax residency—provided you actually meet all the requirements and really move to Portugal.

But here too, the tax benefits do not happen automatically with the visa. You will need to actively change your tax residency and set up the necessary structures.

The fundamental differences at a glance

You see: We’re talking about completely different concepts. That explains why so many entrepreneurs make the wrong decision.

Estonia’s e-Residency: What you’ll really find—and why it’s no cure-all

I am an e-Resident in Estonia myself. So I can tell you firsthand: It’s a brilliant system—but not what many expect.

The reality of e-Residency

Since its launch in 2014, more than 100,000 people have opted for e-Residency. Over 20,000 companies have been founded.

But here’s the catch: Most of these entrepreneurs gained nothing tax-wise.

Why? Because they continue to run their business from Germany. And that means: German tax obligations remain.

When e-Residency makes tax sense

There are absolutely scenarios where e-Residency brings tax advantages:

• You’re already non-resident in Germany and looking for an EU business structure
• Your business runs fully automated without active trading
• You work remotely and spend fewer than 183 days in Germany
• You have passive income streams like royalties or dividends

In these cases you benefit from Estonia’s unique system: Profits are only taxed when distributed. That means retained profits remain tax-free.

The practical advantages of e-Residency

Beyond the tax issue, e-Residency has real benefits:

1. Digital efficiency: All dealings online, available 24/7
2. EU market access: SEPA payments, EU invoicing with no hassle
3. Low bureaucracy: Year-end closing often in a few clicks
4. International credibility: An EU company opens doors

The hidden costs and drawbacks

What many providers conceal from you:

• Bookkeeping costs: €100-300 monthly for professional support
• Language barrier: Dealing with authorities only in Estonian or English
• Time zone difference: Support often only during Estonian business hours
• Bank account issues: German banks scrutinise Estonian companies

Additionally, many German banks consider you risky if you run an Estonian company. This can lead to account closures.

Tax pitfalls with e-Residency

This is critical: Even if you meet all requirements, there are traps:

Substance problem: The German tax office increasingly checks the economic substance of foreign companies. If the business is in fact run from Germany, it may be classified as a shell company.

This means: German tax obligation remains despite an Estonian company.

That’s why I recommend: Get tax advice before founding. The €2,000-5,000 for solid analysis can save you tens of thousands in back taxes later on.

Portugals D2 Visa: The path to physical EU residency for digital nomads

The D2 Visa is Portugal’s answer to the remote working trend. And unlike e-Residency, you can actually change your tax residency here.

But—as you may already know—there are strings attached.

What the D2 Visa really offers

The D2 Visa is a residence permit for self-employed people and freelancers. It allows you to:

• Live legally in Portugal with full work rights
• Access the EU single market without additional visas
• Route to citizenship after five years’ residence
• Tax optimisation via NHR status (more on that soon)

Sounds tempting. But let’s check the reality.

The true requirements

This is where things get serious. Portugal checks closely:

1. Proof of funds: At least €7,200 in your account (minimum wage × 12)
2. Business plan: Detailed plan for your self-employment
3. Health insurance: Full cover for Portugal
4. Police clearance: From all countries of residence in the last 5 years
5. Proof of residence: Rental contract or property purchase

The business plan is critical. You have to prove you can and will work from Portugal. A simple I work remotely won’t cut it.

NHR status: Portugal’s tax ace

This gets interesting: As a new tax resident, you can apply for NHR status (Non-Habitual Resident). That means:

• Foreign income is often tax-free (under certain conditions)
• Portuguese income gets a flat tax rate up to 20% for certain professions
• 10 year limit without extension possible

Sounds fantastic, right? But here’s the big catch.

The NHR trap: Why many are disappointed

Portugal has toughened NHR rules. Those who already have the status can keep it. New applicants currently have poor chances.

This means: The main advantage of the D2 Visa has largely vanished.

Still, moving can pay off. Portugal’s standard income tax is 14.5% to 48%—for many German entrepreneurs still more attractive than the German tax rates.

Practical challenges with the D2 Visa

From my consulting work, I know the main stumbling blocks:

Costs of the D2 Visa path

Expect these expenses:

• Application fees: €83 for the visa, €72 for residence permit
• Lawyer/advisor: €3,000-8,000 for full service
• Translations: €500–1,500 for all documents
• Housing: Deposit and first rent (varies)
• Tax advisor: €2,000–5,000 for setup

All in all, you should allow €10,000–20,000 for the full process.

That’s not a small sum. But if you want to change your tax residency long term, it’s a worthwhile investment.

Tax realities: An honest comparison of both options

Now to the heart of the matter: What do both options really mean for you, tax-wise?

I’ll show you three concrete scenarios with real numbers. No theory—just practice.

Scenario 1: The online marketing expert (€150,000 annual profit)

Thomas, 34, runs an online marketing agency. His clients are international, he works fully remotely.

Status quo in Germany:

• Trade tax: €5,250 (3.5% at a rate of 400%)
• Corporation tax: €37,500 (25%)
• Solidarity surcharge: €2,063
• Private withdrawal (€100,000): €26,375 capital gains tax
• Total tax: €71,188 (47.5%)

With e-Residency Estonia:

If Thomas gives up German tax residency and only retains profits:

• Estonian tax: €0 (only on payout)
• German tax: €0 (non-resident)
• Savings: €71,188

But: He must prove the business is run from Estonia. That’s tough for online marketing.

With D2 Visa Portugal (without NHR):

• Portuguese corporation tax: €31,500 (21%)
• Private withdrawal: €17,750 (23.6% average)
• Total tax: €49,250 (32.8%)
• Savings: €21,938

Scenario 2: The consultant (€80,000 annual profit)

Maria, 41, advises German businesses in digital transformation. She has strong local ties.

With e-Residency: No tax advantages, as her work clearly takes place in Germany.

With D2 Visa: Possible, but she would have to relocate her business to Portugal. That’s hard with close German client ties.

Scenario 3: The software developer (€200,000 annual profit)

Robert, 39, sells software licences internationally. His business is mostly automated.

Status quo in Germany:

• Total tax: €97,125 (48.6%)

With e-Residency:

Perfect scenario for Estonia, since the business is automated:

• Tax on retained earnings: €0
• Savings: €97,125

With D2 Visa Portugal:

• Total tax: €67,500 (33.75%)
• Savings: €29,625

The truth about substance requirements

This is critical: German tax offices check more and more thoroughly. They ask:

• Where are business decisions made?
• Where is your server/IT infrastructure?
• Where do you communicate with customers from?
• Where is your centre of life?

With e-Residency, it’s much harder to show real substance. Portugal, with physical presence, has a clear advantage here.

My practical tip for tax planning

Never choose a structure just for tax savings. The best solution is the one that fits your life and business and is still tax-optimised.

I’ve seen too many entrepreneurs get tangled up in complexity just to save a few percent. In the end, it cost them more time and money than an honest, simple solution.

Practical decision help: Which path fits you?

After more than 1,000 consultations, I can tell you: There is no “best” solution. There’s only the best for your situation.

That’s why I developed a decision tree to offer clarity.

The Estonia check: When e-Residency works

e-Residency is right for you if you can answer all the following with “Yes”:

1. Are you willing to give up German tax residency?
2. Is your business largely automated or location-independent?
3. Do you have no regular German clients/partners?
4. Can you prove business decisions are not made in Germany?
5. Are you prepared to forgo immediate profit distributions?

If you answer even one with “No”, e-Residency is risky for you tax-wise.

The Portugal check: When the D2 Visa makes sense

The D2 Visa is for you if you can answer at least 4 of the following with “Yes”:

1. Are you willing to actually move to Portugal?
2. Can you run your business from Portugal?
3. Do you have €15,000–25,000 for the move?
4. Do you speak English or Portuguese?
5. Are you patient enough for 6–12 months processing time?
6. Do you want to stay long-term (5+ years) in the EU?
7. Is a warm climate and relaxed lifestyle important to you?

The alternative: Use both

This is where it gets interesting: You can combine both paths.

For example:

1. Start immediately: e-Residency for initial international structure
2. Prepare in parallel: D2 Visa application for a long-term solution
3. Switch after moving: From Estonian to Portuguese structure

Many of my clients use this hybrid strategy. It gives you time and flexibility.

Checklist: Your next steps

Depending on your choice, initiate these steps:

For e-Residency Estonia:

• Tax pre-analysis by specialists (€2,000–3,000)
• Plan for substance relocation
• e-Residency application (online, about 3–4 weeks)
• Company formation and bank account
• Deregister from Germany (if possible)

For D2 Visa Portugal:

• Find a lawyer/advisor in Portugal
• Develop a business plan
• Gather and translate all documents
• Rent an apartment in Portugal
• Visa application at the Portuguese consulate

Both options:

• German tax advice for exit strategy
• International tax advice for new structure
• Legally secure documentation of all steps

Avoid the most common mistakes

I see these mistakes time and again:

Mistake 1: Setting up a structure quickly without tax pre-analysis
Mistake 2: Ending German tax residency without an alternative plan
Mistake 3: Complex structures with no real benefit
Mistake 4: Underestimating substance requirements

Take your time deciding. A year of preparation can save you decades of problems.

My recommendation for different entrepreneur types: Which path leads to your goal?

After this thorough comparison, you might be asking: Okay Richard, but what should I do?

Based on my experience with hundreds of international entrepreneurs, heres my honest assessment for different profiles.

Type 1: The location-independent freelancer

Profile: Web designer, programmer, translator, online marketer
Revenue: €50,000–150,000/year
Clients: International

My recommendation: e-Residency Estonia

Why? You already check all the boxes:

• Location-independent work
• International clients
• Digital mindset
• Flexible lifestyle

Important: Create genuine substance. Spend at least 3–4 months a year in Estonia or other EU countries. Keep precise records of your stays.

Type 2: The established consulting entrepreneur

Profile: Management consultant, coach, lawyer
Revenue: €200,000–500,000/year
Clients: Mainly Germany/DACH

My recommendation: Caution with both options

Honestly: Moving abroad is tricky for you. Your clients are local, your expertise anchored in the German market.

Better: Optimise your German structure. A well-designed GmbH with profit retention already brings significant tax advantages.

If you still want to go abroad: Portugal via D2 Visa, but only with a long-term plan to internationalise your client base.

Type 3: The e-commerce entrepreneur

Profile: Amazon FBA, Shopify store, dropshipping
Revenue: €100,000–300,000/year
Clients: Europe, USA

My recommendation: Hybrid approach

1. Phase 1: e-Residency for EU structure and SEPA access
2. Phase 2: D2 Visa for personal security
3. Phase 3: Potential move to Portuguese holding structure

E-commerce is ideal for international structures. You have real substance (warehousing, logistics), which you can move flexibly.

Type 4: The SaaS founder

Profile: Software-as-a-Service, app development
Revenue: €50,000–1,000,000+/year
Clients: Global

My recommendation: Definitely e-Residency

You are the ideal candidate for Estonia:

• Digital product
• Scalable technology
• International clients
• High profit margins

Use Estonias retention model for fast growth. Invest saved tax in product development and marketing.

Type 5: The investment entrepreneur

Profile: Real estate investor, trader, asset manager
Revenue: Variable, often passive
Clients: Not relevant

My recommendation: Portugal with D2 Visa

Why? Investors benefit from:

• Attractive property tax regime in Portugal
• EU capital market access
• Stable legal framework
• High quality of life

Also: You have the means for the more involved D2 Visa process.

Type 6: The content creator

Profile: YouTuber, influencer, online course creator
Revenue: €75,000–250,000/year
Clients: Social media, international

My recommendation: Portugal via D2 Visa

Content creators benefit from:

• Copyright and IP protection in the EU
• Favourable tax on royalties
• Inspiration from a new setting
• New content material from changing locations

Plus: Portugal is a popular creator destination. Youll quickly find a community.

Type 7: The lifestyle entrepreneur

Profile: Various online projects, location-independent
Revenue: €60,000–120,000/year
Clients: Mixed

My recommendation: Try Portugal first, decide later

Many lifestyle entrepreneurs overestimate their flexibility. So:

1. Spend 6 months in Portugal (tourist visa)
2. Test business from there
3. If successful: apply for D2 Visa
4. If not: e-Residency as plan B

My personal advice

Whatever your type—don’t rush. I always recommend this process:

1. Assessment: Where do you stand for tax purposes today?
2. Goal setting: What do you want to achieve?
3. Feasibility check: What is realistically possible?
4. Trial phase: Try it out first
5. Execution: Then take the full step

And remember: Both paths—e-Residency and D2 Visa—are not one-way streets. You can always adjust or switch back.

This gives you the peace of mind to make a careful decision.

Have questions about your specific case? Let’s talk. As your tax mentor, I’m happy to support you on this journey.

Your RMS

Frequently asked questions

Can I have both e-Residency and a D2 Visa at the same time?

Yes, it’s possible. e-Residency is a digital service, not a residence title. You can apply for the D2 Visa simultaneously and combine both options.

Do I ever have to travel to Estonia for e-Residency?

No, you don’t need to go to Estonia for e-Residency itself. But for tax substance, physical presence in the EU is recommended. Many e-Residents visit Estonia once a year.

How long does the D2 Visa application process really take?

In practice, 6–12 months. The official 60 days only count from submission of all documents. Gatherings docs usually takes 4–8 months.

Can I keep a German bank account with e-Residency?

That depends on your bank. Many German banks are wary of Estonian companies. Inform your bank of your plans in advance to avoid having your account closed.

What happens to my German health insurance?

When you give up German tax residency, you usually lose your German health insurance too. You’ll need new cover in your target country or an international policy.

Is NHR status really no longer available in Portugal?

Portugal has tightened NHR rules. Those who already have NHR keep it until the end of the 10-year period. New applicants currently have slim chances.

What are the running costs for both options?

e-Residency: €1,000–3,000 yearly (bookkeeping, compliance). D2 Visa: €2,000–5,000 yearly (tax consultant, lawyer, renewal of residence permit).

Can I use e-Residency as an employee?

e-Residency is aimed at entrepreneurs. Employees normally don’t benefit tax-wise. The D2 Visa is also for the self-employed.

What about family reunification?

e-Residency is personal to you. With the D2 Visa, spouses and children under 18 can apply together. Separate applications and evidence are needed.

How legally secure are both options?

Both programs are established and legally secure. e-Residency has run since 2014, the D2 Visa since 2007. Changes are usually announced in advance and apply only to new applications.