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 including 10% flat tax on foreign pensions, 0% on most foreign-source dividends and gains under treaty conditions, and 20% flat tax on Portuguese-source income in high-value-added professions. The regime drew significant HNW migration, particularly from France, the UK (post-Brexit), and the US. The 2024 budget largely closed the regime to new electors, replacing it with the much narrower IFICI (Tax Incentive for Scientific Research and Innovation).
The relevant tax regime
- Income tax (IRS). Progressive to 53% top marginal (including state and solidarity surcharges).
- Capital-gains tax. Generally 28% on securities; 28% to 53% on real estate.
- Inheritance and gift. No inheritance tax on transfers between spouses, parents, and children. 10% stamp duty on other transfers.
- VAT. 23% standard.
- IMI. Annual property tax.
- AIMI. Additional property tax on property values above €600,000.
NHR transition and IFICI
The NHR regime closed to new electors after 31 March 2024 (with grandfathering of existing electors and various transition provisions). The IFICI successor regime applies to specific professional categories: scientific research, higher education, and certain technology-sector roles, with 20% flat rate on Portuguese-source income in qualifying activities for 10 years.
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. Golden Visa real-estate investment route closed in 2023 (with grandfathering); cultural and capital investment 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 closure to new electors (2024). Golden Visa real-estate route closure (2023). IFICI introduction. Continued AIMI adjustments on high-value real estate.
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.
Primary Sources
- Código do IRS (Decreto-Lei 442-A/88).
- NHR regime: Artigos 16.º, 72.º e 81.º do Código do IRS (revoked for new electors in 2024).
- Lei n.º 82/2023 (Orçamento do Estado 2024; NHR closure and IFICI introduction).
- Código do IMI; AIMI provisions.
- FATCA Model 1 IGA between U.S. and Portugal.
- Autoridade Tributária e Aduaneira — info.portaldasfinancas.gov.pt.
Reviewed May 2026