NHR is closed. What that means if you hold it
No new registrations. Existing holders keep the terms they registered under, and the ten year clock keeps running.
The non habitual resident regime was closed to new arrivals and replaced by IFICI. A transitional window let some applicants still register into March 2025. If you are inside the regime, nothing about your grant changed. If you are arriving now, NHR is not available to you and IFICI is the regime to look at.
- ClosedNo new registrations, outside the transitional window that has now passed
- 10 yearsExisting grants continue for their remaining years
- IFICIThe regime that replaced it for new arrivals
Two regimes, and the differences that decide between them
For anyone still earning, the two regimes look broadly similar on Portuguese work income. For anyone drawing a pension, they are not comparable at all.
NHR, nobody new. IFICI, new arrivals who qualify.
IFICI requires that you were not a Portuguese tax resident in the previous five years, and that you have not previously used NHR or Programa Regressar. Holding NHR once rules IFICI out.
Autoridade Tributária, IFICI FAQIFICI turns on the activity, not the person.
Where NHR worked from a list of high value added activities, IFICI runs through seven categories tied to the employer and the activity, each signed off by a different authority. Qualifying is a certification exercise, not a self assessment.
Autoridade Tributária, IFICI information leafletExcluded from IFICI entirely.
Pension income sits outside IFICI and is taxed at ordinary progressive rates. If you hold NHR, the treatment set out in your own grant is what governs, and it is worth checking against what a move would cost you.
Autoridade Tributária, IFICI FAQSide by side
The comparison that matters, on the points where the two regimes actually diverge.
- Open to new applicants
- NHR: no. IFICI: yes, if you meet the five year non residence test and have not used NHR before
- Portuguese work income
- IFICI: a flat 20% on income from a qualifying activity
- Foreign dividends, interest, gains, rent, royalties
- IFICI: exempt, except from blacklisted jurisdictions, which are taxed at 35%
- Pensions
- IFICI: excluded, and taxed at progressive rates
- Duration
- Both run for ten consecutive years. Under IFICI the window runs from the year you became tax resident, and registering late shortens it
- How you qualify
- IFICI: through one of seven certified categories of activity, each with its own authority
Arriving now? IFICI is your regime, if you qualify at all
The question is not whether you can still get NHR. It is whether your activity and your employer fall into one of the seven IFICI categories, and if they do not, whether the ordinary Portuguese rules still make the move worthwhile. That is a different conversation, and worth having before you move rather than after.
Common questions
The ones we answer on almost every call, and the ones the market most often gets wrong.
Can I still register for NHR?
No. The regime closed to new entrants, and the transitional window that allowed some late registrations has passed. IFICI is the regime for new arrivals.
I already hold NHR. Has anything changed for me?
No. Existing grants continue on their original terms for their remaining years. The closure applies to new registrations.
Can I switch from NHR to IFICI?
No. Having previously used NHR rules you out of IFICI, as does having used Programa Regressar.
What happens when my ten years end?
You fall into the ordinary Portuguese rules. That is worth modelling a year or two ahead rather than in the final month, because for some income profiles it changes where it makes sense to be resident.
Talk to us
We advise founders, investors and executives on both sides of this: the tax position and the residency route, together rather than separately.
Book a call with Fernando
Fifteen or thirty minutes, by Microsoft Teams. Fernando Ferreira, General Partner at Ventures.eu.
