Part II · Jurisdictions · No. 17

Portugal

An EU and eurozone member that operated the Non-Habitual Resident regime as one of Europe's most permissive tax-residency programs from 2009 to 2023. The regime has been substantially curtailed; a narrower successor regime targets specific professional categories. Portugal nonetheless remains a high-value destination for HNW migration.

Why this jurisdiction matters

Portugal's Non-Habitual Resident regime (NHR), enacted in 2009, provided a 10-year tax-residency benefit: exemption for most foreign-source dividends, interest, rents and gains where they could be taxed in the source state under a treaty (or similar conditions), foreign pensions exempt (10% for registrations from April 2020), and a 20% flat tax on Portuguese-source employment and self-employment income from high-value-added activities. The regime drew significant HNW migration, particularly from France, the UK (post-Brexit), and the US. The 2024 State Budget (Lei 82/2023) closed the regime to new entrants from 1 January 2024, apart from transitional cases, and replaced it with the much narrower IFICI (Incentivo Fiscal à Investigação Científica e Inovação, informally “NHR 2.0”), set out in Article 58-A of the Tax Benefits Statute (EBF).

The relevant tax regime

• Income tax (IRS). Progressive to 48%, plus a solidarity surcharge of 2.5% (income €80,000–€250,000) and 5% (above €250,000), so the combined top marginal rate is 53% (2026 brackets).
• Capital-gains tax. Generally 28% flat on securities (with optional aggregation). For residents, 50% of a real-estate gain is added to other income and taxed at progressive rates, with a reinvestment exemption for the main home.
• Inheritance and gift. No inheritance tax as such. Stamp duty of 10% applies to gratuitous transfers, with transfers to spouses, civil partners, descendants and ascendants exempt (0.8% stamp duty still applies to transfers of Portuguese real estate).
• VAT. 23% standard.
• IMI. Annual property tax.
• AIMI. Additional annual tax on residential property held by individuals with aggregate taxable value above €600,000 (€1.2 million for jointly taxed couples), at 0.7% to 1.5% for individuals.

NHR transition and IFICI

The NHR regime closed to new entrants from 1 January 2024. Existing beneficiaries keep the remainder of their 10-year period, and a transitional rule allowed certain people who became resident in 2024, under arrangements already in place by the end of 2023, to register. The IFICI successor regime (EBF Art. 58-A, regulated by Portaria 352/2024/1) is limited to qualifying activities: higher-education teaching and scientific research, qualifying jobs in certified startups and in companies benefiting from certain investment tax incentives, and specified highly qualified roles. It gives a 20% flat rate on Portuguese-source employment and self-employment income from those activities for 10 years. Most foreign-source employment, business, investment, rental and capital-gains income is exempt (with progression), except income from blacklisted jurisdictions. Foreign pensions get no IFICI benefit.

Registration or residency mechanics

Portuguese tax residency requires either 183-day presence or maintenance of habitual abode. NHR registration was via Finanças by 31 March of the year following first residency. The Golden Visa real-estate and capital-transfer routes closed in October 2023 (Lei 56/2023, “Mais Habitação”), with grandfathering for existing holders. Investment-fund, research, cultural-heritage and job-creation routes continue.

Reporting and disclosure

CRS participant. FATCA Model 1 IGA. Foreign-asset reporting required. Beneficial-ownership register.

The substance question

Portuguese residency is determined under Article 16 of the IRS Code. NHR/IFICI elections require substantive Portuguese residency. Treaty-residence questions are resolved under standard tie-breaker rules.

Recent changes

NHR closed to new entrants from 2024 (Lei 82/2023). Golden Visa real-estate route closed in October 2023 (Lei 56/2023). IFICI was introduced for 2024 onward and made operational by Portaria 352/2024/1 (December 2024). IRS brackets are indexed annually. Figures as of October 2026.

Common asset classes parked here

• Trophy real estate — Lisbon, Cascais, Algarve.
• HNW residency under legacy NHR and Golden Visa programs.
• EU passport residence for non-EU HNW.
• Yachts — Mediterranean and Atlantic moorage.

Reviewed October 2026