NHR: closed
The non-habitual resident regime (2009–2023) gave ten years of 20 % tax on Portuguese income from listed professions and exempted most foreign income, with foreign pensions at 10 % from 2020. It closed to new registrations on 1 January 2024; people registered by then keep their remaining years, and 2024 arrivals with a 2023 contract, lease or visa could still enter under the transitional rule. Nobody arriving in 2026 can obtain it.
For Swiss retirees it worked cleanly, because the convention sends pensions and the AHV to Portugal: 10 % here, nothing in Switzerland (with source tax on pension-fund payments refunded). That combination is gone.
- Closed since 1 January 2024; existing holders keep their ten years
- IFICI: 20 % on Portuguese income from listed activities for ten years; foreign income exempt with progression; pensions excluded
- 15 % Swiss withholding on dividends after reclaim, and nothing Portuguese under IFICI
- 15 January registration deadline
IFICI: who qualifies and what it does
Eligibility: no Portuguese tax residence in the previous five years, no past NHR, and income from a listed activity — higher-education teaching and research, qualified posts under contractual investment incentives or RFAI, listed industrial and service companies exporting at least 50 %, companies recognised by AICEP or IAPMEI, R&D staff eligible for SIFIDE, certified start-ups, activities in the Azores and Madeira. Effects: 20 % on the Portuguese employment or business income from the activity, for ten years; foreign salaries, business income, dividends, interest, rents and gains exempt in Portugal with progression (art. 81.º n.º 4); pensions taxed normally. Registration with the competent body by 15 January of the year after arrival.
What it means for Swiss income
| Swiss-source income of an IFICI resident | Switzerland | Portugal |
|---|---|---|
| Dividends from Swiss companies | 35 % withheld, 20 points refunded, 15 % final (5 % for a 25 % corporate holding) | exempt (progression only) |
| Interest from Swiss banks | 35 % withheld, refunded down to 10 % | exempt |
| Gains on Swiss shares | none | exempt — where 28 % would otherwise apply |
| Rent from Swiss property | Swiss cantonal tax | exempt with progression |
| Salary for work done in Portugal, paid by a Swiss employer | none (not Swiss-source) | 20 % only if the Portuguese activity is listed; a Swiss employer without a Portuguese presence usually does not qualify |
| AHV, second-pillar pension, lump sums | none (refund of source tax) | taxed at 12,5–48 % after 4 587 € — outside IFICI |
For a Swiss investor who takes a qualifying job, IFICI removes the Portuguese 28 % on the portfolio and leaves the treaty rates in Switzerland — a real saving, protected by the treaty’s own articles for dividends and interest, which carry no subject-to-tax clause.
Retirees: what remains
Ordinary taxation: AHV and pension-fund income at the progressive rates after the 4 587 € deduction, joint filing for couples, no Swiss tax, no wealth tax, 28 % on capital income. The treaty page explains the refund of Swiss source tax on pension payments and lump sums. Timing the second-pillar capital withdrawal before Portuguese residence remains the main lever.
Steps
Five-year check
No Portuguese residence in 2021–2025 for a 2026 arrival; no NHR ever.
Qualify the job
Employer's certification or CAE code and the profession list checked before signing.
Register by 15 January
With the competent body; the return applies the 20 % and the exemptions.
Swiss reclaims
Form 90 for withholding tax; residence certificate for the pension fund; IFICI changes nothing on the Swiss side.
We check IFICI eligibility, file the registration, and prepare the Portuguese return with the exemptions and the Swiss items in their categories, alongside the Swiss refund claims. Ask whether your job qualifies.
Questions
I still hold NHR. Is my Swiss pension taxed at 10 %?
Yes, until your ten years end — and the Swiss refund of source tax on pension-fund payments has been granted on proof of the 10 % Portuguese taxation. New arrivals pay the ordinary progressive rates.
Does IFICI help a Swiss investor who does not work?
No. It requires income from a listed activity in Portugal. Without it, the ordinary regime applies: 28 % on dividends and gains (with holding-period reductions), no wealth tax, treaty rates in Switzerland.
Is Swiss lump-sum taxation available to Swiss citizens returning from Portugal?
A Swiss citizen cannot use lump-sum taxation on return to Switzerland; it is reserved for foreign nationals taking up residence without Swiss employment. That is a Swiss question for your fiduciary, not a Portuguese one.
Sources and official references
- Estatuto dos Benefícios Fiscais, artigo 58.º-A — IFICI: activities, 20 % for ten years, five years of non-residence, NHR beneficiaries excluded — checked 18.9.2026
- Portaria n.º 352/2024/1 — IFICI registration by 15 January — checked 18.9.2026
- Código do IRS, artigo 81.º n.º 4 — exemption with progression for IFICI beneficiaries' foreign income of categories A, B, E, F, G — checked 18.9.2026
- Fedlex — Convention Switzerland–Portugal: art. 10 (dividends 5 % / 15 %), 11 (10 %), 13 (gains: residence state), 18 and 21 (pensions, AHV: residence state) — checked 18.9.2026
- ESTV — impôt anticipé 35 %, refundable to treaty residents — checked 18.9.2026