The original NHR regime was repealed from 1 January 2024. Existing registered beneficiaries can generally use their benefits until the end of the original period, with a limited transition for certain moves completed by the end of 2024. For new plans, IFICI offers a targeted incentive for qualifying work. The tax authority explains existing and transitional cases.
In October 2023, Portuguese Prime Minister António Costa announced the end of the Non-Habitual Resident (NHR) tax regime. Since its introduction, the system had attracted retirees, freelancers and employees from across Europe moving to Portugal. It offered tax relief for expatriates and formed part of the effort to attract foreign investment. However, with a deepening housing crisis and social protests on the streets, the left-wing party Bloco de Esquerda (Left Bloc) pushed not only for the end of the system but also for stricter limitations on property purchases by non-residents.
Golden Visa and tax planning
Portugal wants to remain attractive to international newcomers. In a Bloomberg interview on 6 June 2025, minister António Leitão Amaro discussed possible changes to Golden Visa and tax incentives for new residents without announcing specific measures. For your move, the useful starting point is to connect two elements: a suitable residence route and the tax options available for your work and income.
The Golden Visa gives eligible investors a residence route into Portugal. Current routes include specified fund and business investments, research funding and cultural support, each with its own conditions and thresholds. Property purchases have not qualified for new applications since the 2023 reform. Alongside the residence route comes the tax planning of your actual home and income: the appropriate permit and an attainable tax status serve as two elements of relocation planning.
A Signal to High-Net-Worth Individuals
The discussion was a signal to wealthy newcomers: Portugal was considering how to continue attracting foreign investment. While the old NHR reached employees, freelancers and retirees, the Golden Visa debate focused on investment-based residence. For entrepreneurs and investors, this suggests a useful sequence: choose the investment and residence route, then establish the tax opportunities from your residence, activity and income sources. IFICI requires qualifying work within the appropriate company or institutional arrangement.
Potential Impact and Assessment
A new tax model could influence wealthy newcomers’ choice of location. Its attraction would depend on how the final conditions fit their income, work and long-term plans.
The debate also shows the close connection between migration policy, housing shortages and the social acceptance of special statuses. For your own plans, calculate the benefits available under current rules and consider possible reforms as additional scenarios. This brings residence rights, your actual home and income sources into one comparison.
Update April 2024: New Tax Rules for Non-Residents (NHR 2.0)
Since 2024, IFICI has provided a separate incentive for specified work in research, innovation and other legally defined areas. Often called “NHR 2.0”, it connects a location decision with tax benefits for professionals whose work and employer or business arrangements qualify. The official FAQs explain access.
What Was the NHR Regime in Portugal?
The NHR regime was considered one of Europe's most generous tax initiatives, offering new tax residents in Portugal significant tax relief for a period of 10 years. It was used as a tool to attract foreign investment and stimulate the national economy. The political debate in 2023 questioned whether this special status remained justified in a changed social and economic landscape.
Which NHR situation applies to you?
- Already registered as NHRBenefits generally continue until the end of your original ten-year period.
- Moved by the end of 2024Limited transition: establish tax residence and the required earlier links to Portugal.
- Planning a move todayCurrent ordinary rules apply; IFICI requires qualifying work and the other eligibility conditions.
Impact on the Portuguese Property Market
The proposal from Bloco de Esquerda went further: Mariana Mortágua, the party’s coordinator, called at the time for an immediate end to NHR and restrictions on selling homes to non-resident foreigners. The concern was that a final rush of investors during the transition could worsen the housing crisis.
Portugal’s sunny climate and lifestyle continue to appeal to expatriates. Your choice of location can bring together the life you want to lead, the tax opportunities available to you and housing costs in the areas you are considering.
These changes raise a broader question: how will tax policy and housing costs influence Portugal’s appeal to foreign investors and expats?
Why Did It End?
Costa announced the closure against a background of rising housing prices and living costs. Existing NHR beneficiaries can at the same time generally continue within their original ten-year period. That gives them a defined horizon for the next part of their life in Portugal.
The limited transition requires, among other conditions, tax residence by the end of 2024 and specified earlier links to Portugal. The normal deadline for registration taking effect from 2024 was 31 March 2025. A later approved application takes effect only from its application year and does not extend the original period.
What Are the Alternatives?
For entrepreneurs planning their residence and business together, Malta offers another EU location to consider. In a qualifying structure, the Maltese corporate-tax refund can reduce the effective burden on active business profits to approximately 5%. Residence, actual management and distributions are incorporated into your personal plan.
Our core expertise lies in company formation in Malta and related Maltese matters. DW&P supports the steps from the initial assessment through structure, formation and relocation to ongoing support. You have one point of contact for the successive stages of your plans in Malta.
Conclusion
The changes to Portugal’s NHR regime reflect a broader trend of countries reviewing their tax programmes and incentives. Each change can also bring opportunities.
Existing NHR holders can use their remaining period as a planning horizon. New arrivals can compare current rules and, where relevant, the IFICI requirements. Portugal’s quality of life remains part of that decision alongside the tax opportunities.
Would you also like to consider Malta for yourself and your business? Book a free initial meeting. We will discuss your starting position and the appropriate next step for your plans in Malta.
This article does not replace individual tax advice.
Sources
- AT: Register as a non-habitual resident - repeal and transitional conditions
- AT: IFICI - frequently asked questions
- AT: Incentivo Fiscal à Investigação Científica e Inovação - booklet
- AIMA: Residence permit for investment activity (ARI) - FAQs
- Bloomberg – Interview mit António Leitão Amaro, 6. Juni 2025
