NHR: the story, briefly
From 2009 the non-habitual resident regime exempted most foreign income for ten years and, from 2020, taxed foreign pensions at 10 %. Under the 2002 treaty, Swedish private pensions were taxable only in Portugal — so Swedish retirees paid nothing, then 10 %. Sweden asked to renegotiate, then gave notice; the treaty ceased on 1 January 2022. Portugal closed NHR to new entrants on 1 January 2024. People registered by then keep their remaining years — but without a treaty, Sweden taxes their Swedish pensions under SINK regardless of NHR, and the 10 % Portuguese rate is credited against nothing.
- Closed since 1 January 2024; existing holders keep their ten years
- IFICI: 20 % for ten years on Portuguese income from listed activities; foreign income exempt with progression; pensions excluded
- SINK 22,5 % on Swedish pensions and 30 % on Swedish dividends apply whatever Portugal does
- 15 January registration deadline
IFICI for a Swede
Eligibility: not resident in Portugal in the previous five years, no past NHR, and income from a listed activity — higher-education teaching and research, qualified jobs 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 with progression; pensions taxed normally. Registration with the competent body by 15 January of the year after arrival.
How Swedish income fares under IFICI
| Swedish-source income | Sweden | Portugal under IFICI |
|---|---|---|
| Dividends from Swedish shares | 30 % coupon tax, final | exempt (progression only) |
| Interest | none | exempt |
| Gains on Swedish shares within ten years of leaving | 30 % | exempt |
| Rent from a Swedish flat | Swedish tax | exempt with progression |
| Salary from a Swedish employer for work done in Portugal | none (not Swedish-source) | 20 % only if the Portuguese activity qualifies — a Swedish employer with no Portuguese presence usually does not |
| Pensions | SINK 22,5 % | taxed at 12,5–48 % after 4 587 €, credit capped at the Portuguese tax |
Without a treaty, IFICI’s exemption on Swedish dividends is a real exemption on the Portuguese side and changes nothing on the Swedish side: 30 % remains the cost. For a Swede with a portfolio of Swedish shares, IFICI removes the Portuguese 28 % and leaves the Swedish 30 %; only non-Swedish holdings escape both.
Retirees: nothing replaces NHR
A Swedish pensioner arriving in 2026 pays SINK in Sweden and Portuguese progressive tax with a capped credit — in practice the higher of the two, which below roughly 50 000 € of pension is the Swedish 22,5 %. Joint filing halves the Portuguese side for couples. There is no Portuguese regime for pensions.
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 the contract.
Register by 15 January
With the competent body; the return applies the 20 % and the exemptions.
Swedish side
SINK decision for pensions; coupon tax at source on dividends; ten-year rule on share sales — none reduced by IFICI.
We check IFICI eligibility, file the registration, and prepare the return with the exemptions, the pension credit and the Swedish items in their categories. Ask whether your job qualifies.
Questions
I hold NHR until 2028. Does it still help against Sweden?
No. Sweden taxes your Swedish pensions under SINK because there is no treaty, and Portugal's 10 % NHR rate is charged on top with credit only up to that 10 %. Your total is the Swedish 22,5 % (20 % from 2027).
Can I switch from NHR to IFICI?
No — former NHR beneficiaries are excluded from IFICI.
Does IFICI exempt my Swedish company's dividends?
In Portugal, yes (with progression). Sweden's 30 % coupon tax still applies; a Swedish AB owned by a Portuguese resident individual has no treaty rate to fall back on.
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 1 unilateral credit; n.º 4 exemption with progression for IFICI beneficiaries' foreign income — checked 18.9.2026
- Autoridade Tributária — treaty table 2026: Sweden's convention ceased to apply on 1.1.2022 — checked 18.9.2026
- Skatteverket — 2026: SINK 22,5 %; coupon tax 30 % on dividends — checked 18.9.2026