1. The Original NHR Regime (2009–2023) – Now Closed
The original Non-Habitual Resident (NHR) regime was one of Europe’s most attractive tax programs for expats, retirees, and remote workers. It offered some very generous benefits:
– 10-year duration (one-time only, not renewable)
– 20% flat tax on Portuguese-sourced income from certain high-value professions
– Exemptions on most foreign income, including employment income, dividends, interest, royalties, and rental income
– Foreign pensions taxed at 10% (introduced later).
The old NHR regime was closed to new applicants in January 2024, with a transitional window until March 31, 2025.
2. The Current Regime: NHR 2.0 (IFICI)
The official name is Fiscal Incentive for Scientific Research and Innovation (IFICI), also known as NHR 2.0. It may last for 10 consecutive years and is non-renewable.
The following conditions must be met to make a taxpayer eligible for the regime:
– She must become a Portuguese tax resident after January 1, 2024
– She has not been a Portuguese tax resident in the previous five years
– She has not benefited from the old NHR regime
– She meets professional and educational criteria
Eligible professions include university professors, medical doctors, engineers, ICT specialists, company directors, and scientific researchers.
Education requirements:
– EQF Level 6 (Bachelor’s degree plus three years of relevant experience), or
– EQF Level 8 (PhD) Qualifying companies must export at least 50% of their turnover or operate in innovation or technology sectors. They must confirm annually, before March 15, that they still meet the requirements.
3. Tax Benefits Under NHR 2.0
– Expat meeting the above conditions and being employed by the qualifying company or self-employed may benefit from 20% flat tax on employment or self-employment income
– She may also enjoy an exemption from Portuguese tax on most foreign-sourced income, including employment income, business profits, interest, dividends, rental income, royalties, and (pending regulation) capital gains.
Foreign pensions are no longer tax-advantaged and are taxed at standard progressive rates from 14.5% to 53%. Note that, although foreign income may be exempt, it is still considered when calculating the progressive tax rate applied to other Portuguese-sourced income. Income from tax-haven jurisdictions is excluded from the exemption and is subject to a flat 35% tax.
4. Application Process
Applications must be filed via Portal das Finanças by January 15 of the year following the start of Portuguese tax residency. Late applications will only apply from the year they are submitted. Required documents include a Portuguese tax number (NIF) with local fiscal address, proof of eligible profession and education, and evidence of employment or activity in a qualifying sector. Company directors must also provide a commercial registry certificate.
5. Practical Considerations
Portugal has no wealth tax and no inheritance tax for spouses, descendants, or ascendants. The country has over 80 double tax treaties, reducing the risk of double taxation.
This regime is best suited for highly skilled professionals and is no longer ideal for retirees whose main income comes from foreign pensions.
