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Tax Planning

Portugal's NHR Programme: An Unexpected Reprieve Following the PM's Resignation?

Costa’s resignation brought fresh uncertainty to the NHR debate in 2023. See what followed, which benefits existing holders retain and how to approach your location plans today.

The NHR regime was repealed from 1 January 2024. Existing registered beneficiaries generally retain their benefits for the rest of the original ten-year period, and certain moves completed by the end of 2024 fall within transitional rules. This gives the 2023 news a practical context today: your existing status and documented relocation history guide the next stage of planning. The tax authority explains these cases.

In a surprising turn of events, the resignation of Prime Minister António Costa in 2023 brought fresh uncertainty to the debate over Portugal’s sought-after Non-Habitual Resident (NHR) tax regime. Would plans to close the scheme still proceed as expected? For expatriates and investors, the political upheaval raised hopes of a reprieve, but left the future of the programme unsettled.

Portugal and NHR: What Became of the Reprieve

The NHR regime, known for attracting investors and expatriates, was originally due to close to new applicants at the end of 2023. Costa’s resignation raised hopes of a delay. The eventual outcome was repeal from 2024, with existing rights preserved and a limited transitional route. For people whose move was already underway, the documents and relevant dates became the central question.

Expert Advice: How to Handle the NHR Situation

Anyone planning a move at the time faced an uncertain political situation. Today, identifying your position provides a clear starting point: those registered as NHR on 1 January 2024 can generally use the benefits for the rest of their original ten-year period. That leaves a defined period for planning income and assets.

A limited transition covers certain people who became tax resident by the end of 2024 and can document the required earlier links to Portugal. The normal registration deadline for effect from 2024 was 31 March 2025. A later approved registration runs from the application year to the original end of the benefit period. Bring together the documents from your move and establish the time remaining.

If you are starting your relocation plans today, consider the current Portuguese rules, the targeted IFICI incentive where relevant, and other EU locations suited to your situation. Entrepreneurs can also consider Malta, where residence, an operating business and ongoing support form part of the same planning decision.

NHR: which dates still matter?

  1. 2023: Political debateCosta’s resignation raised hopes that closure might be delayed.
  2. 1 January 2024: RepealExisting registered beneficiaries generally retain the remainder of their original term.
  3. End of 2024: Transition cutoffCertain arrivals had to become tax resident by this date and document earlier links to Portugal.
  4. 31 March 2025: Normal deadlineRegistration deadline for effect from 2024. Later approved applications take effect from the application year.
Late registration does not extend the original term. New relocation plans follow today’s rules.

Sources: 1

This article does not replace individual tax advice.

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