Was hat die NHR-Regelung 2024 ersetzt?

Kurze Antwort
Zuletzt geprüft 15 October 2026

Portugal closed the non-habitual resident (NHR) regime to new applicants from 1 January 2024. It was replaced by the tax incentive for scientific research and innovation (IFICI), often called "NHR 2.0". IFICI applies a 20% rate to eligible Portuguese employment and self-employment income for 10 years, but only for specific qualifying activities.

Es hängt ab von

Your activity

IFICI covers teaching and research, qualified roles in certified or recognised companies, R&D staff and startup employees, not retirement or passive income as such.

Your residence history

You must not have been tax resident in Portugal in the previous five years or have used NHR, Programa Regressar or IFICI before.

Timing

Registration is due by 15 January of the year after you become resident; late requests shorten the benefit period.

Wer es braucht

This matters to professionals from Germany considering Portugal for work in research, higher education, technology or another highly qualified role with an eligible employer. Retirees and people living on investment income generally gain little from IFICI, because it rewards specific professional activities and foreign pensions are not among the exempt categories. People already registered under NHR keep it for the rest of their 10-year period, and a closed group could still join under transitional rules for 2024. Anyone weighing a move should check the activity criteria and the German side, including the double taxation agreement and exit questions, with a qualified tax adviser.

Wie es funktioniert

  1. 1

    Confirm prior non-residence

    You must not have been Portuguese tax resident in any of the previous five years, nor have benefited from NHR, Programa Regressar or IFICI.

  2. 2

    Check that your activity qualifies

    Eligible activities are set out in art. 58.º-A of the Tax Benefits Statute (EBF) and Portaria n.º 352/2024/1; most require certification by FCT, AICEP, IAPMEI, ANI or Startup Portugal.

  3. 3

    Become tax resident

    Residence usually follows from more than 183 days in Portugal in a 12-month period, or from keeping a home there as your habitual residence.

  4. 4

    Register on the Portal das Finanças

    Submit the IFICI request; once it is filed, employers can withhold tax at 20%.

    by 15 January of the following year
  5. 5

    File annual returns

    Eligible Portuguese income is taxed at 20%, while most foreign employment, business, capital, rental and capital-gains income is exempt; income from listed low-tax jurisdictions is taxed at 35%.

Was es kostet

PostenBetragHinweis
Tax on eligible Portuguese employment and self-employment income20%2
Tax on income from listed low-tax jurisdictionsGenerally exempt for categories A, B, E, F and G; 35% if paid by entities in listed low-tax jurisdictions2

Wichtige Fakten

FaktWertQuelleGeprüft
NHR (Residente Não Habitual): availability for new residentsRevoked from 1 January 20241 geprüft 15 October 2026
NHR transitional rule for 2024Tax residence by 31 December 2024 plus a qualifying tie (e.g. work contract by 31 December 2023; lease, property promise or school enrolment by 10 October 2023)1 geprüft 15 October 2026
IFICI ('NHR 2.0'): rate on eligible Portuguese employment and self-employment income20%2 geprüft 15 October 2026
IFICI: duration10 consecutive years2 geprüft 15 October 2026
IFICI: prior non-residence conditionNot tax resident in Portugal in any of the previous 5 years2 geprüft 15 October 2026
IFICI: registration deadlineBy 15 January of the year after becoming tax resident2 geprüft 15 October 2026
IFICI: foreign-source incomeGenerally exempt for categories A, B, E, F and G; 35% if paid by entities in listed low-tax jurisdictions2 geprüft 15 October 2026
Tax residency testMore than 183 days in any 12-month period starting or ending in the tax year, or a home held as habitual residence3 geprüft 15 October 2026

Häufige Fehler

  • Assuming IFICI treats pensions like NHR did; foreign pensions are not among the exempt categories.
  • Missing the 15 January registration deadline, which shortens the 10-year period.
  • Moving before confirming that the employer or role is certified for an eligible activity.
  • Overlooking the five-year prior non-residence condition after earlier stays in Portugal.

FAQ

Is NHR completely gone?

For new residents, yes. NHR was revoked from 1 January 2024, with transitional rules in the 2024 State Budget law (Lei n.º 82/2023). People already registered keep it until their 10-year period ends. The transitional rule covered people who became resident by 31 December 2024 and had qualifying ties, such as a work contract by 31 December 2023 or a lease by 10 October 2023.

Can retirees use IFICI?

Generally not to much effect. IFICI is linked to qualifying professional activities such as research, teaching, highly qualified jobs in eligible companies and work for certified startups, and foreign pensions are not among the foreign income categories it exempts. Retirees moving from Germany should review the double taxation agreement and the general Portuguese rules with a tax adviser.

Do remote workers for a German employer qualify?

Usually not, unless the role fits one of the listed activities. Most IFICI categories depend on the Portuguese employer or entity being certified or recognised, for example by AICEP, IAPMEI, ANI or Startup Portugal, or on teaching and research. Check eligibility with the certifying body or a tax adviser before relying on the 20% rate in your planning.

How is foreign income treated under IFICI?

Most foreign-source employment, self-employment, capital, rental and capital-gains income is exempt in Portugal for the 10-year period, while income paid by entities in jurisdictions on Portugal's list of clearly more favourable tax regimes is taxed at 35%. An exemption in Portugal does not mean the income is untaxed elsewhere; the source country may still tax it under the relevant treaty.

Quellen

  1. Autoridade Tributária e Aduaneira, Residente Não Habitual – RNH: inscrição nas Finanças (May 2024) (öffnet sich in einem neuen Tab)Authority · geprüft 15 October 2026
  2. Autoridade Tributária e Aduaneira, Incentivo fiscal à investigação científica e inovação (IFICI) – folheto informativo (March 2025) (öffnet sich in einem neuen Tab)Authority · geprüft 15 October 2026
  3. Autoridade Tributária e Aduaneira – Portal das Finanças, Alteração de não residente para residente (cidadãos estrangeiros) (öffnet sich in einem neuen Tab)Authority · geprüft 15 October 2026

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