cityparity

Is NHR still available in Portugal? No, and the replacement is narrower than the name suggests

By Skyler Bissell · September 4, 2026 · 9 min read

Portugal closed the non-habitual resident regime to new applicants on 1 January 2024, and the last people who could still use the old rules had to be tax resident by 31 December 2024. That makes the answer a flat No for anyone arriving now. The reason the question keeps getting asked is that a replacement arrived carrying the same 20% headline rate and a nickname, NHR 2.0, which implies the old regime came back. It did not. This page gives the dates, says who is still covered, and puts the two regimes side by side.

The short answer. NHR is closed to new applicants and has been since 1 January 2024. If you already hold it, you keep it for your full 10 consecutive years on the old terms. If you are moving to Portugal now, the regime to look at is IFICI, which shares the 20% rate and the 10-year term and adds a test that runs through your employer rather than through you.

TL;DR

The dates that decide it

The non-habitual resident regime was created by Decreto-Lei n.o 249/2009 and ran for fourteen years. The 2024 State Budget Law terminated it for new entrants with effect from 1 January 2024, and built a transitional bridge for people who had already committed to the move before the announcement landed. Those transitional conditions are where almost all of the confusion lives, because they are a set of dates rather than a single one.

To use the old rules after the closure, a person had to clear three separate hurdles. They had to be registered as NHR by 1 January 2024, or meet the tax residency conditions by 31 December 2023. They had to become a Portuguese tax resident during 2024. And they had to show one qualifying act, already completed, from a defined list: a lease or property possession agreement, a property purchase reservation, or a child enrolled in a Portuguese school, each dated on or before 10 October 2023, or an employment contract, a secondment agreement, or a valid residence visa or permit dated on or before 31 December 2023. Those dates come from the RFF Lawyers summary of the transitional regime.

One number circulates on its own and misleads people: 31 March 2025. It reads like a final deadline open to anyone, and it was nothing of the kind. Registration for NHR has always been due by 31 March of the year following the year residency begins, so for someone whose residency started during 2024 that ordinary deadline happened to fall on 31 March 2025. It was the last date on which a person who had already met every 2023 and 2024 condition could file the paperwork. It was never a route in for someone who had not.

A late registration, filed after that deadline, does not extend anything. The regime still runs to the end of its 10-year term counted from the residency year, so filing late costs the years already spent rather than pushing the finish line back.

If you already hold NHR, nothing changed

The closure was prospective. Someone who registered in 2019 or 2021 keeps the regime for 10 consecutive years counted from the year of registration, on the terms that applied when they joined, including the flat 20% rate on qualifying Portuguese-source income from a high-value activity. A 2021 registration therefore runs into 2030 and expires on its own schedule.

The practical thing to know is that the clock counts calendar years and it does not pause. Time spent outside Portugal inside the 10-year window is time spent, and there is no mechanism to bank it. If you are inside the window, the useful exercise is working out what your Portuguese tax bill looks like the year after it ends, which is the same exercise readers of the Dutch and Spanish regimes have to do. The shape of that cliff is covered in expat tax breaks, decoded.

NHR against IFICI, line by line

The two regimes rhyme on the headline and diverge underneath. IFICI is governed by Ordinance 352/2024 and article 58-A of the Tax Benefits Statute, and the Sovereign Group summary is the source for the rows specific to it. Here is what a mover is choosing between, if they even have a choice.

Feature NHR (closed) IFICI (open)
Headline rate NHR: 20% flat on qualifying Portuguese income IFICI: 20% flat on Portuguese employment and professional income
Duration NHR: 10 consecutive years IFICI: 10 consecutive years
Who the test runs on NHR: the individual and their listed high-value activity IFICI: the employer or the activity, which must hold certification
Foreign pension income NHR: taxed at 10% IFICI: fully taxable at ordinary rates
Other foreign-source income NHR: broadly exempt IFICI: largely exempt where a double tax agreement or the OECD model applies
Registration deadline NHR: 31 March of the year after residency begins IFICI: 15 January of the year after residency begins
Certifying bodies NHR: none, the activity list did the work IFICI: FCT, AICEP, IAPMEI, ANI or Startup Portugal
Open to new applicants NHR: No, closed 1 January 2024 IFICI: Yes

Two rows carry most of the practical weight. The pension row is what turned a large group of retirees away from Portugal, because a 10% rate on a foreign pension was the entire reason many of them chose it, and IFICI taxes that income in full. The certification row is what turns away a working professional, because eligibility stopped being a question about the individual's occupation and became a question about the company that hired them. A full account of that gate, and the activity routes behind it, sits in the companion piece on Portugal's IFICI regime.

How to tell which regime you fall under

Three questions settle it, in order. First, did you register as an NHR, and in which year? If the answer is a year, you are grandfathered and your end date is that year plus nine. Second, did you become a Portuguese tax resident during 2024 while holding a qualifying act signed in 2023? If so, you may be inside the transitional route, and the registration should already have been filed. Third, if neither is true, NHR is unavailable and IFICI is the only regime on the table, subject to your employer clearing the certification test.

There is a fourth case worth naming because it is common and quietly expensive. Someone moved to Portugal in 2025 or 2026, assumed the 20% rate applied because a relocation site said Portugal has a 20% expat rate, and has been budgeting on that basis. They are on the standard IRS schedule. Portugal's ordinary rates run to 48% before the solidarity surcharge, so the gap between the assumption and the bill is no rounding error.

Why our Lisbon figures show no 20% rate

cityparity's engine deliberately does not apply the Portuguese regime to take-home. Run the published single professional scenario into Lisbon and the engine returns an equivalent salary of €96,792, which is $112,158 at current rates, on a gross of €129,000 taxed at an effective 45.6% against New York's 31.1%. That Lisbon rate is the standard IRS and social security result, and it is what the great majority of arriving professionals will pay.

The reasoning sits in the city data file itself, and it is a judgement we would rather state than bury. Every qualifying route into IFICI gates on the employer holding a certification, so a software engineer joining an ordinary Portuguese company misses out even when their own skills are exactly what the regime says it wants. Modelling the 20% rate as the default would flatter Portugal by roughly the width of the entire regime, and it would do so silently, on a page a reader might use to accept an offer. Where a regime does move take-home in our engine, as with the Dutch 30% ruling and the Spanish Beckham regime, we apply it and say so. For Portugal it is carried as a note.

That decision has an honest cost, and it belongs on the page: if you do clear the IFICI gate, our Lisbon and Porto figures understate what you keep. The check is worth making before you rely on either number. To see where Portugal sits once the regime question is set aside, take-home pay by country ranks the standard result across every country we model, and the New York to Lisbon comparison shows the same household line by line.

FAQ

Can I still apply for NHR in Portugal in 2026?

No. Every route into the old regime required becoming a Portuguese tax resident by 31 December 2024, and the qualifying acts behind those routes had to be signed in 2023. There is no application open in 2026. The regime that is open is IFICI, and it is a different test with a different form.

I registered for NHR in 2021. Does the closure affect me?

No. The closure applies to new entrants. An existing holder keeps the regime for the full 10 consecutive years counted from the year they registered, on the terms in force when they joined. A 2021 registration runs its course into 2030.

Is IFICI the same thing as NHR 2.0?

NHR 2.0 is a nickname that advisers and property marketers use for IFICI. The statutory name is Incentivo Fiscal a Investigacao Cientifica e Inovacao. The nickname is a large part of why people believe NHR reopened, because it suggests a second version of a regime they already recognise rather than a narrower incentive with an employer test.

Does NHR or IFICI reduce the tax on my Portuguese salary automatically?

Neither is automatic. Both require registration by a deadline, and IFICI additionally requires the employer or the activity to be certified by one of the Portuguese agencies that administer it. cityparity's engine therefore prices Lisbon and Porto at the standard IRS rates and treats the 20% rate as a note rather than a discount, because the ordinary case is that a mover does not clear the gate.

Sources and how to check this

The transitional dates and the 10-year grandfathering come from RFF Lawyers, read on 4 September 2026. The IFICI rate, term, pension treatment, 15 January deadline and list of certifying bodies come from the Sovereign Group, read the same day. Both are professional firm summaries rather than the statute, and we say so: the underlying instruments are Decreto-Lei n.o 249/2009 for NHR, the 2024 State Budget Law for the closure, and Ordinance 352/2024 with article 58-A of the Tax Benefits Statute for IFICI. Anyone relying on this for a filing decision should read those instruments or take advice, because a firm summary is a map and the statute is the ground.

Our own figures come from the engine described in the methodology, computed on the published single professional scenario. They are the standard-regime result for Portugal by design.

If you are weighing Portugal against the regimes that do move the number, Spain and the Netherlands are the two worth putting beside it, and both behave differently from what you have just read. Run your own two cities and your own salary on the cityparity calculator before you take anyone's headline rate at face value, including ours.