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Non-habitual resident (NHR) is closed — IFICI, the regime that replaced it

For fourteen years the non-habitual resident regime — 20 % on listed professions, 10 % on foreign pensions, exemptions on foreign income — was why many chose Portugal. It closed to new residents on 1 January 2024. Its replacement, IFICI, keeps the 20 % only for research, innovation and qualified jobs in some companies.

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


Accountant reviewing a tax report at her desk

NHR: what it was, and who still has it

The residente não habitual status (2009–2023) gave a new tax resident ten years of: a 20 % flat rate on Portuguese employment and self-employment income from “high value-added” professions, exemption of most foreign-source income under treaty rules, and — from 2020 — a 10 % rate on foreign pensions. Lei n.º 82/2023 (the 2024 State Budget) ended it for anyone who became resident from 1 January 2024, with transitional entry for people who could prove, by 31 March 2025, that their move had been decided in 2023 (a lease, a contract, a visa application, enrolment of children). Those admitted keep their ten years; nothing else survives.

If a website or an adviser still quotes “NHR: 10 % on pensions” for a 2026 move, the information is out of date.

  • Closed to new residents since 1 January 2024
  • IFICI: 20 % on employment and self-employment income from listed activities, 10 years
  • 5 years of non-residence required before the move; former NHR beneficiaries excluded
  • 15 January registration deadline for the year after you become resident

IFICI: the regime that exists in 2026

Article 58.º-A of the Estatuto dos Benefícios Fiscais — Incentivo Fiscal à Investigação Científica e Inovação — applies to a person who becomes tax resident in Portugal, was not resident in any of the previous five years, and exercises one of these activities:

ActivityRegistered with
aHigher-education teaching and scientific research, including scientific employment in entities of the national science and technology system; jobs and board seats in recognised technology and innovation centresFCT
bQualified jobs and board seats under contractual investment benefits (Código Fiscal do Investimento, chapter II)AICEP
cHighly qualified professions (list by ministerial order; meanwhile Portaria n.º 12/2010) in companies that benefit from the RFAI investment regime, or in industrial and service companies with listed CAE codes that export at least 50 % of turnoverAT
dOther qualified jobs and board seats in entities recognised by AICEP or IAPMEI as relevant to the national economyIAPMEI / AICEP
eR&D staff whose costs qualify for the SIFIDE tax creditANI
fJobs and board seats in certified start-ups (Lei n.º 21/2023)Startup Portugal
gJobs and activities of tax residents of the Azores and Madeira, under regional lawthe Regions

The benefit: employment (category A) and self-employment (category B) income from those activities is taxed at a special rate of 20 % for ten consecutive years from the year of registration as resident, with the option to aggregate instead. Other income — pensions, rents, dividends, foreign salaries outside the activity — follows the ordinary rules. The right applies year by year while you remain resident and keep earning from a listed activity (a gap of up to six months between activities is tolerated).

Excluded: anyone who benefited from NHR or opted for the young-taxpayer regime (art. 12.º-A CIRS), and income from jobs covered by art. 22.º n.º 2 c) of the investment code. The regime can be used once in a lifetime.

The deadline that decides everything

Portaria n.º 352/2024/1 sets the registration: with the competent entity (FCT, AICEP, IAPMEI, ANI, Startup Portugal, the Regions, or the AT for professions under c)) by 15 January of the year following the year in which you became resident. A late registration is accepted but the 20 % rate applies only from the year of registration, for the remaining years of the ten.

Someone who becomes resident in September 2026 therefore registers by 15 January 2027 and, if eligible, pays 20 % on the qualifying income of 2026 onwards.

Eligibility depends on facts about the employer as much as the employee: exports over 50 %, RFAI benefits, start-up certification, recognition by AICEP or IAPMEI. Access Portugal's accountants check the employer's position before a client relies on the 20 % rate — and put the answer in writing, because ten years of tax planning rest on it.

If you do not qualify

Ordinary Portuguese taxation: progressive IRS brackets on worldwide income once you are resident, with double-tax treaties allocating pensions, salaries and property income between Portugal and the source country, and credits for foreign tax. For many retirees the effective rate on a modest pension is lower than the headline brackets suggest; for high earners it is not. The country-by-country pages under tax and accounting show the treaties and the arithmetic; the practical option for some — the golden visa’s minimal presence, which avoids tax residence — is described on the golden visa page.

Questions

I am a remote software engineer for a foreign company. IFICI?

Only if the job falls under a listed activity with a registered Portuguese entity — for instance employment by a certified Portuguese start-up or a qualifying exporting company. A foreign employer with no Portuguese presence does not fit any of a) to g).

Does IFICI cover pensions?

No. Only categories A and B (employment and self-employment) from the listed activities. Pensions are taxed at ordinary rates, subject to the treaty with the paying country.

Can I keep NHR if I already have it?

Yes, for the ten years granted, as long as you remain resident. Leaving Portugal and returning later does not create a new NHR.

Is IFICI automatic?

No. Registration with the competent entity and the AT, within the deadline, is required; the AT then applies the rate in the annual IRS return.

Sources and official references

  1. Estatuto dos Benefícios Fiscais, art. 58.º-A — IFICI: activities a) to g), 20 % rate on categories A and B for 10 years, no prior residence in 5 years, NHR beneficiaries excluded, registration rules — checked 18.9.2026
  2. Portaria n.º 352/2024/1, de 23 de dezembro — IFICI regulation: registration by 15 January of the year following the year of residence, entities (FCT, AICEP, IAPMEI, ANI, Startup Portugal, AT) — checked 18.9.2026
  3. Lei n.º 82/2023 (State Budget 2024) — end of the NHR regime for new residents from 1 January 2024, transitional cases, creation of art. 58.º-A — checked 18.9.2026
  4. Código do IRS, art. 16.º — tax residence (183 days; habitual home) — checked 18.9.2026
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