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NHR and IFICI for Canadians: what closed, what replaced it, what it is worth

Canadian retirees who read about Portugal's 10 % pension rate are reading about a regime that closed on 1 January 2024. Its successor is built for people who work — researchers, start-up staff, exporting firms — and says nothing about pensions. What IFICI gives a Canadian, and where the 15 % withholding fits.

Updated Facts checked against official sources (listed at the end)


Calculator, pen and glasses on a desk with notes

NHR: closed

The non-habitual resident regime taxed Portuguese income from listed professions at 20 % and exempted most foreign income for ten years, with foreign pensions at 10 % from 2020. It closed to new registrations on 1 January 2024. People registered by then keep their remaining years; 2024 arrivals with a 2023 contract, lease or visa could still enter under the transitional rule. A Canadian arriving in 2026 cannot obtain it.

  • 1 January 2024 NHR closed; holders keep their ten years
  • 20 % IFICI rate on Portuguese income from listed activities, ten years
  • Foreign income exempt in Portugal under IFICI (with progression) — pensions excluded
  • 15 January registration deadline

IFICI: who qualifies

The Incentivo Fiscal à Investigação Científica e Inovação (EBF, art. 58.º-A) is for people who become resident without having been resident in the previous five years and earn income from: higher-education teaching and research; qualified jobs under contractual investment incentives; highly qualified professions in companies under the RFAI regime or in listed industrial and service companies exporting at least 50 % of turnover; qualified jobs in companies recognised by AICEP or IAPMEI; R&D staff eligible for SIFIDE; jobs and board seats in certified start-ups; and activities in the Azores and Madeira. Former NHR beneficiaries are excluded; the regime is used once.

Registration with the competent body (FCT, AICEP, IAPMEI, ANI, Startup Portugal, or the tax authority for the professions list) by 15 January of the year after becoming resident.

What it does with Canadian income

Canadian-source income of an IFICI residentCanadaPortugal
Salary for work done in Portugal, paid by a Canadian employernothing (art. 15) — but the employer must run Portuguese payroll or use an employer of recordPortuguese-source: 20 % only if the employer fits a category (certified start-up, recognised company) — a Canadian company with no Portuguese presence usually does not
Dividends from Canadian shares15 % withholding (art. 10)exempt with progression
Interest0 % under Canadian law for arm’s-length interestexempt
Rent from a Canadian property25 % on gross or section 216 on netexempt with progression
Gains on Canadian sharesdeparture tax on leaving; then residence stateexempt
CPP, OAS, RRSP/RRIF, company pensions15 % on periodic payments above CAD 12 000taxed at 12,5–48 % after the 4 587 € deduction — IFICI does not cover pensions

The pattern for Canadians is friendlier than for Americans: Canada does not tax its citizens abroad, so the Portuguese exemption on dividends, rents and gains is a real exemption, costing only the Canadian withholding. The catch is the salary: IFICI’s 20 % needs a Portuguese qualifying employer or activity; a remote job for a Toronto firm is taxed at the ordinary rates unless the firm sets up here in a qualifying form.

Worked example

A Canadian engineer hired by a certified Lisbon start-up at 80 000 €, with C$20 000 of Canadian dividends:

  • Without IFICI: about 23 300 € of IRS on the salary (after deducting the 11 % contributions, 8 800 €), plus 28 % on the dividends (about 13 500 € → 3 800 €) with the 15 % Canadian withholding credited.
  • With IFICI: 20 % of 71 200 € = 14 200 € on the salary; dividends exempt in Portugal (they only lift the rate on other income, irrelevant under the flat 20 %); Canada keeps its 15 %.

Saving: about 11 000 € a year for ten years.

Steps

Confirm the five-year rule and the activity

No Portuguese residence since 2021; employer's certification or CAE code and the profession list checked before signing.

Register by 15 January

With the body responsible for your category.

Treaty forms in Canada

NR301 so that Canadian dividends and pensions are withheld at 15 % rather than 25 %.

Annual return

Annex A at 20 %, annex J with the exempt items and the pensions taxed normally.

We check IFICI eligibility against the current lists, file the registration on time and prepare the return with the exemptions and the Canadian credits. Ask whether your contract qualifies.

Questions

I am retiring to Portugal. Is there any regime for my pension?

No. NHR is closed and IFICI excludes pensions. Your CPP, OAS and RRIF income is taxed at the ordinary progressive rates after the 4 587 € deduction, with credit for the 15 % Canadian withholding, and a couple can split the income.

Can I qualify through my own company?

If the company is a certified Portuguese start-up, or is recognised by AICEP or IAPMEI as relevant, and you hold a qualifying post in it — yes. Certification takes months and has substance requirements; it is not a paper exercise.

Does IFICI exempt the gain when I sell my Canadian house?

Foreign capital gains (category G) are exempt with progression in Portugal under IFICI. Canada taxes the gain on Canadian real property regardless (taxable Canadian property), less the principal-residence exemption for the years it was your home.

Sources and official references

  1. Estatuto dos Benefícios Fiscais, artigo 58.º-A — IFICI: eligible activities, 20 % for ten years, five years of non-residence, NHR beneficiaries excluded — checked 18.9.2026
  2. Portaria n.º 352/2024/1 — IFICI registration by 15 January — checked 18.9.2026
  3. Código do IRS, artigo 81.º n.º 4 — exemption with progression for IFICI beneficiaries' foreign income (categories A, B, E, F, G) — checked 18.9.2026
  4. Convention Portugal–Canada, art. 10 (dividends 15 %), art. 18 (pensions) — checked 18.9.2026
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