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• Only Financial analyst in the Group level;
• Decent salary increase of 40%, with additional potential at the end of the year;
• Position is directly under the Group CFO
• Interesting job responsibilities
• Good office, + WFH
• New opportunities and would get me out of my current daily routine
• Great CFO, with significant experience and would be collaborating a lot (i.e. brainstorming)
• Opportunities to expand my skill-set, implement processes as I'd like.

• New job, would need to learn the ins and outs of the company, their systems
• Relatively smaller (Revenue 1/4th the Company i'm working for now)
• New colleagues
• Non-conclusive growth opportunities. CFO has no idea himself, suggested things such as regional finance director.

• Know the in's and out's of the Company. (CFO's main selling point for taking me under her team)
• Appreciated by the management team and supervisory board, salary has more than doubled during the last year, with another coming up with the counter offer expected on Tuesday. ~40%
• Responsible for complex tasks, previously M&A, bond issuance, fundraising, however, as i'd be switching from the investment dpt. to Group Finance, M&A responsibilities would cease.
• CFO mentioned that she will retire after 2 years, which would open up a position for the finance manager to rise to CFO and myself to Finance manager
  • CFO mentioned in case of partial exit, would appoint as CFO of part of the company sold. (Doesn't make sense to me, as the companies have their own financial analysts)
• Fully WFH
• Top 25 company in the country, Largest industry player in the region.
• CFO and CLO are very fond of me
• Ex. Finance manager mentioned that there's a "long position" held on me by a couple members of management board.
• Amazing colleagues across all departments and Group companies
• Opportunities of becoming a CFO in subsidiaries, Group consists of around a dozen companies, all with >10MM EUR revenue (some 50MM+), and only 2 of the companies having a dedicated CFO, everything else passes trough company level financial analysts, which, if I do become the Group FP&A, would end up going trough me to the CFO.
• Leaving would result in cash-out of accrued PTO, ~1 months pay.

• Unclear future position, expecting counter offer, but the CFO and CLO shared the management structure and pointed out where I could be and position something like a Group Financial Analyst, would prefer a higher title however.
• Would be 2 positions below CFO, under a new manager for the finance dpt.
• New manager, not sure if we will be compatible.
• Would get every bit of energy squeezed out of me due to the exit of our investors, as i'd be the one compiling all materials necessary (regional PE)
  • Addition to previous bullet point - Responsibilities might be more focused on preparing materials for our investors exit, rather than FP&A tasks.
• I've already handed in my resignation once before
• High stress, projects with very short deadlines leading to late nights, stressed out management board, pushing down the stress on employees.
• Switching positions internally would require restructuring.

• Only Financial analyst in the Group level;
• Decent salary increase of 40%, with additional potential at the end of the year;
• Position is directly under the Group CFO
• Interesting job responsibilities
• Good office, + WFH
• New opportunities and would get me out of my current daily routine
• Great CFO, with significant experience and would be collaborating a lot (i.e. brainstorming)
• Opportunities to expand my skill-set, implement processes as I'd like.

• New job, would need to learn the ins and outs of the company, their systems
• Relatively smaller (Revenue 1/4th the Company i'm working for now)
• New colleagues
• Non-conclusive growth opportunities. CFO has no idea himself, suggested things such as regional finance director.

• Know the in's and out's of the Company. (CFO's main selling point for taking me under her team)
• Appreciated by the management team and supervisory board, salary has more than doubled during the last year, with another coming up with the counter offer expected on Tuesday. ~40%
• Responsible for complex tasks, previously M&A, bond issuance, fundraising, however, as i'd be switching from the investment dpt. to Group Finance, M&A responsibilities would cease.
• CFO mentioned that she will retire after 2 years, which would open up a position for the finance manager to rise to CFO and myself to Finance manager
  • CFO mentioned in case of partial exit, would appoint as CFO of part of the company sold. (Doesn't make sense to me, as the companies have their own financial analysts)
• Fully WFH
• Top 25 company in the country, Largest industry player in the region.
• CFO and CLO are very fond of me

• Unclear future position, expecting counter offer, but the CFO and CLO shared the management structure and pointed out where I could be and position something like a Group Financial Analyst, would prefer a higher title however.
• Would be 2 positions below CFO, under a new manager for the finance dpt.
• New manager, not sure if we will be compatible.
• Would get every bit of energy squeezed out of me due to the exit of our investors, as i'd be the one compiling all materials necessary (regional PE)
  • Addition to previous bullet point - Responsibilities might be more focused on preparing materials for our investors exit, rather than FP&A tasks.
• I've already handed in my resignation once before

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• S-Corp has 2 employees (me and my wife)
• NHR regime can be applied
• From US tax perspective:
  • ($224K = $112,000*2) can be paid as a W2 wage in order to max out Foreign Earned Income Exclusion, taxed at 15% Social security + Medicate tax
  • 100K can be paid as S-Corp Distribution
  • I will need to pay 15% Social security + Medicate tax on 200K W2, and regular US tax bracket on 100K SCorp distribution.
• From Portugal perspective (according to https://www.fresh-portugal.com/blog/how-to-file-your-tax-return-in-portugal-for-2022)
  • Those who work in Portugal (freelance or regular employment) under the NHR tax regime only pay a 20% flat rate on personal income tax
  • S-Corp salary ($224K) is considered as work done in PR, therefore it's PT sourced income and taxed at 20% + SS in Portugal
  • SS taxes in Portugal are 11% (employee) and 23.75% (employer)
  • S-corp distributions is considered as work done in Portugal therefore PT capital income (28%) applies
• Portugal / US treaties
  • Double taxation the treaty provides that you won't be taxed in either country on your wages, salaries, tips, and other compensation from a Portuguese source if you're an employee of a U.S. company that has a permanent establishment in Portugal or if you live in Portugal for 183 days or more during a consecutive period of 12 months.
  • Totalization Agreement: This agreement ensures that US expats working in Portugal will not be subject to dual Social Security taxes. Instead, expats will only have to pay into the Social Security system of their home country. The totalization agreement also guarantees that expats will be eligible for social security benefits from both countries, provided they meet the eligibility criteria.

• Income tax on salary: $224K * 20% = $44.8K
• Income tax on S-Corp distribution: $100K * (11% + 23.75%) = $34.75K
• I don't pay Social Security tax in the US, due to Totalization Agreement

1. Where am I wrong in my calculations and understanding?
2. How do I optimize tax burden?
3. When does Foreign Earned Income Exclusion or Foreign Tax Credit kick in?
4. Will Spain or Italy be a better option for a move from tax perspective?