SlideShare a Scribd company logo
1 of 36
Download to read offline
THE PORTUGUESE NON-HABITUAL
TAX RESIDENT (NHR) REGIME
Frequently Asked Questions &
Reasons to Move to Portugal
Introduction
There are a few things you should know If you are
considering moving to Portugal.
This updated presentation answers the most
frequently asked questions on the Portuguese Non-
Habitual Tax Resident regime and provides some
reasons why Portugal is a great country to live.
3
29th country on the OECD Better Life Index
2020 (1), 1st on InterNations Expat Insider
2022: Quality of Life Index. (2)
According to the 2021 Annual Global
Retirement Index from International Living
Portugal was considered the best country in
Europe to retire to and the 5th best in the
World (3) and as reported by CNBC, Portugal is
the best place to retire abroad. (4)
Portugal (https://en.wikipedia.org/wiki/Portugal) has a number of attractive characteristics:
#01
Quality of Life
Why Portugal?
(1) - https://www.oecdbetterlifeindex.org/countries/portugal/
(2) - https://cms-internationsgmbh.netdna-ssl.com/cdn/file/cms-media/public/2022-07/Expat-Insider-2022-Survey.pdf
(3) - https://internationalliving.com/the-best-places-to-retire/
(4) - https://www.cnbc.com/2020/01/03/the-10-best-places-to-retire-abroad.html
The non-habitual tax resident (NHR) is a tax regime created to improve
Portuguese international competitiveness. This regime targets non-
resident individuals who are likely to establish a permanent or a
temporary residence in Portugal.
The NHR regime establishes, under certain conditions, IRS exemptions
on foreign source income, as well as a limited 20% taxation of income
from employment and independent personal services, in both cases if
deriving from listed high value-added activities.
Entrants in the regime since 1 April 2020 are liable to a 10% tax rate on
pension income, instead of the previous exemption.
FAQ #2
What are the benefits of the NHR regime?
FAQ #1
What is the NHR regime?
Frequently Asked Questions
4
5
Weather and environment quality
(12th country on the OECD 2020
Better Life Index).
Why Portugal?
Estimated 3300 hours of sunshine
per year, one of the highest rates
in Europe.
#02
Weather
#03
Sunshine
▪ Foreign-sourced passive income (interest, dividends, certain royalties, other income from capital, capital gains and income from
immovable property) derived by NHR is exempt (without progression except in the case of capital gains on real estate) in Portugal,
provided that it is potentially liable to taxation in the source State (i) under the rules of an existing Double Tax Treaty (DTT) or (ii) in the
absence thereof, under the rules of the OECD Model Tax Convention if such income is not deemed to arise from a State, region or territory
included in the Portuguese tax havens’ blacklist nor from a Portuguese source under the IRS Code territoriality rules.
▪ Foreign-sourced income from pensions is liable to a 10% rate for Portuguese tax residents as from 1 April 2020. Before that, pensions
were IRS exempt (with progression) if not deemed to arise from a Portuguese source under the IRS Code territoriality rules.
▪ Foreign-sourced employment income is IRS exempt (with progression), provided that it is effectively taxed in the source State (i) under
the rules of a DTT or in, the absence thereof, (ii) of the OECD Model Tax Convention, as long as such income is not deemed to arise from a
Portuguese source under the IRS Code territoriality rules.
▪ Foreign-sourced employment income is IRS exempt (without progression) in Portugal, provided that it is income derived from high value-
added activities of a scientific, artistic or technical nature and it is effectively taxed in the source State (i) under the rules of a DTT or in,
the absence thereof, (ii) of the OECD Model Tax Convention, as long as such income is not deemed to arise from a Portuguese source
under the IRS Code territoriality rules.
▪ Foreign-sourced income from independent personal services is IRS exempt (without progression) in Portugal, provided that it derives
from high value-added activities of a scientific, artistic or technical nature, as defined by Ministerial Order, and is potentially liable to
taxation in the source State (i) under the rules of an existing DTT or (ii) in the absence thereof, under the rules of the OECD Model Tax
Convention, if such income is not deemed to arise from a State, region or territory included in the Portuguese tax havens’ blacklist nor
from a Portuguese source under the IRS Code territoriality rules.
FAQ #3
What types of income are eligible for exemption under NHR regime?
Frequently Asked Questions
6
7
Modern and cosmopolitan country:
Lisbon was elected one of the best places to travel in
2018 (5) and Porto is the best European city to live in
2019. (6)
Lisbon was also ranked the 10th most livable city in
the world in Monocle Quality of Life Survey 2019:
Best Cities to Live (7) and Braga has earned 1st place
on European’s best destinations in 2021. (8)
Portugal has a great list of “wonders” declared a World Heritage Site by Unesco. (9)
Fado (the Portuguese most traditional music genre) was considered by UNESCO Intangible Cultural
Heritage of Humanity, in 2011.
#05
Cultural Offering
#04
Modernity
Why Portugal?
(5) - www.europeanbestdestinations.com/european-best-destinations-2018/
(6) - https://www.europeanbestdestinations.com/best-of-europe/best-destinations-to-live-in-europe-if-you-want-to-leave-the-usa/
(7) - https://monocle.com/magazine/issues/125/quality-of-life-survey/
(8) - https://www.europeanbestdestinations.com/european-best-destinations-2021/
(9) - https://en.wikipedia.org/wiki/List_of_World_Heritage_sites_in_Portugal
Frequently Asked Questions
FAQ #4
What types of income are eligible for reduced rates under
NHR regime?
Income deriving from employment or independent personal services of a domestic or foreign
source but not qualifying for the mentioned exemptions will be liable to autonomous taxation
at a special 20% flat rate and not to the general and progressive IRS rates (currently of up to
53% for yearly taxable income above € 250.000), provided that it derives from high value-added
activities of a scientific, artistic or technical nature. Entrants in the regime that became
Portuguese tax resident as from 1 April 2020 are liable to a 10% tax rate on pension income.
8
Frequently Asked Questions
An amendment to the list of High Value-Added Activities, applicable from 1 January 2020 onwards,
was published on 23 July 2019 (Ministerial Order nr. 230/2019). This was an in-depth revision of the
list of activities that has been in effect since 2010, in order to align them with the needs of the
labour market. Nevertheless, the most recent Ministerial Order encompasses a wide range of
professions and activities according to the Portuguese Classification of Professions (PCP), which
allows for more immediate clarification of interpretive doubts regarding the scope and range of
each of the activities listed in the table.
This new list entered into force on 1 January 2020 and applies to individuals registered under the
NHR regime from 2020 onwards. For NHR registered as such with effect up to 31 December 2019,
even if their registration took place in 2020, the old list still applies. However, these “old entrants”
can also opt to benefit from the new one.
FAQ #5 What are considered high value-added activities of a
scientific, artistic or technical nature?
9
New list of High Value-Added Activities of a Scientific,
Artistic or Technical Nature
(Ministerial Order nr. 230/2019, of 23 July)
I – Professional activities (PCP codes):
112 — General manager and executive manager
12 — Manager of administrative and commercial services (v.g., financial, human resources, and strategy)
13 — Production and specialized services’ managers (v.g., farming, livestock, forestry, fishery, mining industry, transports and others
14 — Managers of hotel business, restaurants/catering, trade and other services
21 —Experts in physics, mathematics, engineering and similar technics (v.g., chemistry, statistics, urban planning, and others)
221 — Doctors (v.g., generalists and experts)
2261 — Dentists and stomatologists
231 — University and higher education professors
25 — IT and communication experts (v.g., software apps, web, etc.)
264 — Authors, journalists and linguists
265 — Creative artists and performing artists (v.g., musicians, cinema producers, actors, dancers, etc.)
31 — Technicians as well as science and engineering professions of intermediate level (v.g., mining industry, life sciences and others)
35 — Technicians of information and communication technologies (v.g., telecommunications and radio)
61 — Farmers and market-oriented skilled agriculture and livestock production workers
62 — Market-oriented skilled forestry, fishery and hunting workers
7 — Skilled industry, construction and crafts workers, including skilled workers of metalwork, food processing, woodwork, clothing, handicraft,
printing, manufacture of precision instruments, jewelers, artisans, electricians and electronics professionals
8 — Facility and machinery operators and assembly workers, namely operators of fixed installations and machinery 10
Professionals' workers included in the above-mentioned professional activities shall possess at least, a
level 4 of the European Qualifications Framework or Level 35 of International Standard Classification of
Education, or five years of duly proven professional experience.
II – Other professional activities:
Directors and managers of companies carrying out productive investment activities may also benefit to
the extent that they are engaged in the projects for which contractual tax benefits have been granted
under the Investment Taxation Code (Código Fiscal do Investimento) enacted by Decree-Law nr.
162/2014, of 31 October 2014.
11
New list of High Value-Added Activities of a Scientific,
Artistic or Technical Nature
(Ministerial Order nr. 230/2019, of 23 July)
1 - Architects, engineers and similar technicians:
101 – Architects
102 – Engineers
103 – Geologists
2 - Visual artists, actors and musicians:
201 – Theater, ballet, film, radio and television Artists
202 – Singers
203 – Sculptors
204 – Musicians
205 – Painters
3 - Auditors:
301 – Auditors
302 – Tax Consultants
4 - Doctors and dentists:
401 – Dentists
402 – Analyst Doctors
403 – Surgeons
404 – Board doctors in ships
405 – General Practitioners
406 – Dentists
407 – Dentist Doctors
408 – Physiatrists
12
Old list of High Value-Added Activities of a Scientific,
Artistic or Technical Nature
(Ministerial Order nr. 12/2010, of 7 January)
6 - Psychologists:
601 – Psychologists
5 - Teachers:
501 – University professors
409 – Gastroenterologists
410 – Ophthalmologists
411 – Orthopedists
412 – Otorhinolaryngologists
413 – Paediatricians
414 – Radiologists
415 – Doctors in other specialties
7 - Professional services, technicians and
similar:
701 – Archaeologists
702 – Biologists and experts in life sciences
703 – Computer Programmers
704 – Consulting and computer programming and
activities related to information and computer
technology
705 – Computer programming activities
706 – Computer consultancy activities
707 – Management and operation of computer
equipment
708 – Activities of information services
709 – Activities of data processing, hosting information
and related activities/Web portals
710 – Activities of data processing, hosting information
and related activities
711 – Other information service activities
712 – Activities of news agencies
713 – Other information service activities
714 – Scientific research and development
715 – Research and development of science physical and
natural
716 – Research and development in biotechnology
717 – Designers
8 - Investors, administrators and managers:
801 – Investors, administrators and managers of
companies promoting productive investment, if allocated
to eligible projects under tax benefits contracts awarded
under the Tax Code for Investment, approved by Decree-
Law nr. 249/2009, of 23 September
802 – Senior employees of companies
13
Old list of High Value-Added Activities of a Scientific,
Artistic or Technical Nature
(Ministerial Order nr. 12/2010, of 7 January)
14
The Portuguese gastronomy is as rich and
diverse as its heritage and landscapes and has
recently been internationally recognised with
33 Michelin star restaurants, totaling 34 stars,
in 2022. (10)
Portugal is also one of the best wine tourism
destinations. Our country had 675 prizes at
the 2022’s Decanter World Wines Awards
(DWWA) (11) and also achieved 296 Medals in
the 2022’s Concours Mondial de Bruxelles. (12)
#06
Gastronomy
Why Portugal?
(10) - https://guide.michelin.com/pt/pt_PT/article/news-and-views/novidades-guia-michelin-portugal-2022
(11) - https://awards.decanter.com/DWWA/2022/
(12) - http://results.concoursmondial.com/index.php
(13) - https://universitas21.com/sites/default/files/2020-
04/U21_Rankings%20Report_0320_Final_LR%20Single.pdf
(14) - www.ef.edu.pt/epi/regions/europe/portugal/ 15
A large part of the population speaks foreign languages,
especially English, Spanish and French.
Portugal was ranked 7th out of 112 countries in the EF
Global English Proficiency Index 2022. (14)
There is a significant number of International Schools
throughout Portugal, attended by both Portuguese and
foreign students.
Portugal is ranked as the 25th best in the World
according to the 2020 U21 Ranking of National Higher
Education Systems. (13)
#08
Other Languages Spoken
#07
Education
Why Portugal?
Frequently Asked Questions
16
Individuals who become resident for tax purposes in Portugal
without having been so in the previous five years.
▪ Staying for more than 183 days in the Portuguese territory, whether these days are
consecutive or not, in any 12-month period beginning or ending in a given tax year;
▪ If staying for a shorter period, having in the Portuguese territory, on any day of the
period referred above, a dwelling under circumstances that lead to the presumption
of an intention to hold and occupy it as a place of habitual abode;
▪ Being, on 31 December, a crew member of a ship or aircraft at the service of an
entity with residence, head office or effective management in Portugal.
FAQ #7
How do I acquire tax residence in Portugal?
FAQ #6
Who may apply for the NHR regime?
Frequently Asked Questions
17
Registering as a tax resident in Portugal is a requirement to obtain the non-habitual resident status,
which means that those wishing to apply for the regime generally must:
i. register as non-resident taxpayers;
ii. obtain residence permits (for non-EU nationals) and residence certificates (for EU nationals);
iii. register as tax residents; and
iv. only then apply for the non-habitual resident status.
FAQ #8
What is the procedure to register as tax resident in Portugal?
18
About 300 daily flights from Portugal to
foreign countries.
Porto Airport ranks among the best airports
in Europe since 2006. (15)
Portugal ranked 16th among 117 countries
in the 2021 WEF Travel & Tourism
Competitiveness Index. (16)
#09
Daily Flights
#10
Convenient Location
for Globetrotters
Why Portugal?
(15) - https://aci.aero/programs-and-services/asq/asq-awards-and-recognition/
(16) - https://www3.weforum.org/docs/WEF_Travel_Tourism_Development_2021.pdf
19
Top conditions for sports (sailing, diving, biking, trekking,
horse riding, golf - with some of the best World courses (17)).
#11
Sports
Why Portugal?
(17) - https://worldgolfawards.com/award/world-best-golf-destination/2018
https://worldgolfawards.com/award/world-best-golf-destination/2017
https://worldgolfawards.com/award/world-best-golf-destination/2016
https://worldgolfawards.com/award/world-best-golf-destination/2015
https://worldgolfawards.com/award/world-best-golf-destination/2014
Frequently Asked Questions
20
Non-habitual resident individuals may enjoy such status for a ten-year period, after which they will be taxed under
the standard IRS regime.
FAQ #10
For how long may I enjoy the NHR status?
An application must be submitted until 31 March of the tax year following that in which Portuguese tax residence is
acquired. From 2 August 2016 onwards, the applications must be submitted on the tax authorities’ website. Moreover,
individuals must submit a statement whereby they solemnly declare that they have not fulfilled the criteria necessary
for being considered a Portuguese tax resident during the preceding five years.
FAQ #9
How do I apply for the NHR status?
After obtaining the non-habitual resident status it will be necessary to file annual tax returns in Portugal, stating the
worldwide income and expenses, for which adequate documentation keeping is required.
FAQ #11
Once I have the NHR status, what are my tax obligations?
(18) - https://www.numbeo.com/cost-of-living/country_result.jsp?country=Portugal 21
Value for money in real estate investments (which
have undergone significant decreases from 2008 to
2015).
In comparison with other major European
countries, Portugal is highly affordable. (18)
#12
Investments
#13
Cost of Living
Why Portugal?
Frequently Asked Questions
22
The NHR status is granted for a ten-year period. The particular features of the NHR regime may always be amended by
law, for better or for worse, even for those who have been granted NHR status prior to the enactment of any change
(although in such cases the degree of change to the regime which is admissible under Portuguese constitutional law is
very debatable).
The State Budget Law for 2020 introduced a 10% tax rate on pension income for new entrants in the regime that
became Portuguese tax resident as from 1 April 2020. Old entrants into the NHR regime (those that became Portuguese
tax residents before 1 April 2020) were grandfathered from the changes promoted by the State Budget Law for 2020
and remain in the old regime (although, in practice, they have an annual opting out towards the new regime). This is a
very important precedent that shows the political willingness to safeguard the legitimate expectations of taxpayers.
Indeed, those that entered the regime prior to the State Budget Law for 2020 changes kept and will keep the previous
regime until the end of their 10-year tax benefit period.
This regime was implemented in 2009 by a Socialist (center-left wing) government and has remained stable since then.
The current Socialist Government (with parliamentary majority until October 2026), the previous Socialist Government
of 2015-2019 and the previous 2011-2015 government coalition of Social Democrats party and Christian Democrat /
People’s party (center-right wing) have not materially changed the regime. The general perception is of its acceptance
by the community in general and by the main political parties. The only relevant adverse change to the regime, prior to
2020, was the enforcement in 2011 and from 2013 to 2017 of a 3,5% surcharge to employment or independent
personal services income deriving from high value added activities of a scientific, artistic or technical nature obtained by
NHR residents liable to autonomous taxation at a special 20% flat rate.
FAQ #12
For how long are the benefits of the regime granted
and have they changed?
Frequently Asked Questions
23
A new change to the NHR regime could happen, but it is not likely, as the regime was introduced in 2009 by a
government of the same center-left wing party (“Partido Socialista”) as the present government, which has
parliamentary majority until October 2026. Additionally, there is currently no significant public debate or controversy
surrounding the NHR regime.
In any case, if such change happens:
i. Even if NHR status is abolished, it cannot be taken away from those that already have it at the time the change is
approved;
ii. Although the NHR status cannot be taken away, the regime could be made less attractive (reducing the scope of the
exemptions, for instance) even for those that have obtained it in the past. To what extent such change could be made
is very debatable under Portuguese administrative and constitutional law. Some changes would always be admissible,
but in principle a change that would make the NHR regime purely nominal (making NHR and normal residents taxed in
the same way or with only very minor differences) should not be allowed. Assessing the degree of change that is
allowed is very difficult.
FAQ #13
Can the NHR regime change again?
(19) - https://www.pordata.pt/en/Europe/Life+expectancy+at+birth+total+and+by+sex-1260 24
Portugal has a high quality
health system, offering
both public and
private healthcare.
According to PORDATA data base,
the average life expectancy at
birth in Portugal in 2021 was 81,2
years. (19)
#14
Health System
Why Portugal?
Frequently Asked Questions
25
Firstly, the likelihood of a unilateral termination of an existing DTT is very reduced. A renegotiation of DTTs between
Portugal and other States is currently an issue with two Nordic countries, and is driven by the double non-taxation of
private pensions allowed by the combination of the NHR regime with DTTs following the OECD Model Tax Convention.
However, recently, Finland and Sweden terminated the DTT with Portugal. Its application ceased since the start of
2019 and 2022, respectively. There is no longer a restriction on these countries’ right to tax private pensions received
in those countries by NHR. These developments motivated Portugal to unilaterally change its domestic NHR regime in
2020, starting to impose tax on foreign-sourced pension income for entrants into it that became Portuguese tax
resident as from 1 April 2020. Currently, no other States have publicly signaled a will to revise their DTTs with Portugal
due to the NHR regime but we are aware that some negotiations in this regard are taking place with France and
Germany.
FAQ #14
How does the termination or renegotiation of a double tax treaty
(DTT) between Portugal, as my residence State, and an income
source State, affect the NHR regime?
26
Successful conclusion of the Troika’s (International
Monetary Fund, European Central Bank and EU) financial
assistance program (2011-2014) on May 17, 2014.
Portugal is a developed democracy with political and social stability and was
ranked among the countries with the most freedom according to the Freedom of
the World 2022 Report. (20)
Portugal was also ranked 7th out of 179 countries in the 2020 Democracy Report
(21) and was ranked 28th out of 167 countries in the 2021 Economist Intelligence
Unit's Democracy Index. (22)
#16
Economic Progress
#15
Political Stability
Why Portugal?
(20) - https://freedomhouse.org/country/portugal/freedom-world/2022
(21) - www.v-dem.net/media/filer_public/f0/5d/f05d46d8-626f-4b20-8e4e-53d4b134bfcb/democracy_report_2020_low.pdf
(22) - https://en.wikipedia.org/wiki/Democracy_Index
Frequently Asked Questions
27
FAQ #15
Am I required to provide proof of Portuguese tax residence?
As explained in FAQ #7 above there is more than one way to acquire Portuguese tax residence. The 184-day rule is
not mandatory as long as one has, in the Portuguese territory, a dwelling under circumstances that lead to the
presumption of an intention to hold and occupy it as a place of habitual abode. The Portuguese tax residence, in
principle, will not be challenged by the Portuguese Tax Authorities. However, it could be challenged by an income
source State, especially if one spends time in that State. In this regard, a number of precautions are advisable: a)
keeping a calendar that tracks one’s days of stay in Portugal and in other countries; b) avoiding short-term rentals
and frequent address changes within the Portuguese territory from the moment one becomes a tax resident
herein; c) ask for invoices with the Portuguese tax number (NIF) on a recurring basis when one acquires
products/services in Portugal. The latter will allow the individual (i) to better prove his/her effective presence in
Portugal, if challenged, (ii) to benefit from certain deductions on the Portuguese tax assessment, if he/she has
taxable income at standard tax rates, and (iii) also make him/her eligible for a State lottery!
Frequently Asked Questions
28
In November 2015, the Socialist party, with the parliamentary support of three far-left parties (the Left Block, the
Communist and the Green parties) formed a new government. The Socialist party proposed in its electoral program
the reintroduction of inheritance taxation between spouses and direct line descendants for “high value” estates (in
principle those with a taxable value above 1 million Euros, with a rate of 28% applying to the surplus), but “taking
into account the need to avoid phenomena of multiple inheritance taxation”. It was therefore possible that a mild
form of inheritance taxation might be re-introduced in Portugal, but it is not clear how it would target NHR with
non-Portuguese assets, due to the caveat in commas.
Currently, inheritance between direct family is tax exempt, assets outside Portugal are not taxable and when tax is
due on Portuguese assets it is so at a low rate - 10%. The Government Program of 2015 intended to tax those
exempt cases (most notably those of inheritances between direct family). However, the relevant aspects remained
fully uncertain (for instance, if foreign assets would be taxed or not, if donations would be taxed in the same way as
inheritances or not, how should the € 1.000.000 be valued, etc.).
The 2015-2019 legislature went by and the Government apparently gave up on the idea of amending inheritance
taxation. The Socialist party electoral program of 2019 and 2022 and the Socialist government programs for the
legislatures of 2019-2023 and 2022-2026 have no mention whatsoever to changes in inheritance taxation.
Nevertheless, developments on this issue should be monitored.
FAQ #16
What about Gift and Inheritance Taxation in Portugal?
(23) - https://www.visionofhumanity.org/wp-content/uploads/2022/06/GPI-2022-web.pdf 29
According to the 2022′s
Global Peace Index, Portugal
ranks 6th, out of 163
countries. (23)
#17
Peaceful Country
Why Portugal?
(24) - https://www.passportindex.org/byRank.php
(25) - https://nationalityindex.com/# 30
If one of the heads of the household qualifies for
residency in Portugal, all the dependents will
automatically qualify.
Moreover, Portugal has one of the world's most
valuable passports (24) and the Portuguese
citizenship was ranked as the 13th most valuable in
the World by Quality of Nationality Index 2018
(QNI). (25)
#18
Portuguese Passport /
Citizenship
Why Portugal?
31
Portugal is an increasingly sought tourist destination. In 2015, it collected 16 awards in the World
Travel Awards for Europe. In 2016, Portugal outdid itself and beat its own record: 24 awards in the so-
called “Oscars” of European tourism. For the 5th time in the last six years, Portugal was voted as the
“Europe's Leading Destination” at those Awards, proving the internationally recognised dynamism,
quality and consistency of tourism in the country. (26)
#19
Tourism
Why Portugal?
(26) - www.worldtravelawards.com/winners/2022/europe www.worldtravelawards.com/winners/2018/europe
www.worldtravelawards.com/winners/2021/europe www.worldtravelawards.com/winners/2017/europe
www.worldtravelawards.com/winners/2020/europe www.worldtravelawards.com/winners/2016/europe
www.worldtravelawards.com/winners/2019/europe www.worldtravelawards.com/winners/2015/europe
The Portuguese NHR Regime
For more information on our Residence Planning Services, please visit our microsite
www.nonhabitualtaxresident.com or scan the below QR code with your smartphone:
Should you require further information on this issue please check our Information Note
on this subject, available at https://www.slideshare.net/RPBA/rpba-newsletter-the-
portuguese-nonhabitual-tax-resident-regime-253546943
32
Proper legal advice is recommended before any decision is
taken to become a Portuguese tax resident, and more so if
one wishes to take full advantage from the NHR status. RPBA
has an in-depth knowledge and expertise on this regime.
To obtain our professional fees or to book a consultation
please e-mail us (Marta Rêgo): marta.rego@rpba.pt
33
The Portuguese NHR Regime
General warning, disclaimer,
copyright and authorised use
▪ In the preparation of this presentation, every effort has been made to offer current, correct and clearly expressed
information. However, the said information is intended to afford general guidelines only. This presentation reflects
information current at 11 November 2022.
▪ This presentation is distributed with the understanding that RICARDO da PALMA BORGES & ASSOCIADOS,
SOCIEDADE DE ADVOGADOS, S.P., R.L. is not responsible for the result of any actions taken on the basis of
information herein included, nor for any errors or omissions contained herein.
▪ RICARDO da PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. is not attempting through this
work to render legal or tax advice and the information in this presentation should be used as a research tool only,
and not in lieu of individual professional study with respect to client legal matters.
▪ Portuguese domestic legislation, foreign legislation, EU Directives and tax treaties have anti-abuse provisions, and
each client structure should be analysed taking those into account.
▪ RICARDO da PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. is the copyright owner of this
presentation and hereby grants you a non-exclusive, non-transferable license to use this presentation provided that
you do not modify its content in any way, that you keep its proprietary notices of RICARDO da PALMA BORGES &
ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. and that you do not retain any copyright or other proprietary
notices displayed on such content.
34
Recent Tax Recognition
▪ Chambers & Partners – Ricardo Band 1 / RPBA Band 3 (2022 / 2021) | Ricardo Band 2 / RPBA Band 3 (2020 / 2019 / 2018 / 2017 / 2016) | Ricardo Band 1 / RPBA Band
3 (2015 / 2014 / 2013) | Ricardo highlighted in Band 1 in the Private Wealth Law practice area of the High Net Worth (HNW) guide (2021 / 2020 / 2019 / 2018)
▪ Legal 500 – Ricardo, Ana Isabel and Rita are Recommended Lawyers / RPBA Band 2 (2022 / 2021 / 2020 / 2019 / 2018) | RPBA Band 3 (2017 / 2016 / 2015 / 2014 /
2013)
▪ Best Lawyers – Ricardo recognised as "Tax Law Lawyer of the Year” (2017) and ranked under the "Tax Law" practice area and the "Tax Planning" subspecialty (2022 /
2021 / 2020 / 2029 / 2018 / 2017 / 2016 / 2015 / 2014 / 2013 / 2012 / 2011) | Ana Isabel Correia recognised as "Tax Law Lawyer of the Year” (2020) and ranked under
the "Tax Law" practice area (2022 / 2021 / 2020 /2019) / RPBA Tax Law Firm of the Year in Portugal (2020)
▪ Who’s Who Legal – Ricardo ranked as a top lawyer in the Corporate Tax Lawyers directory (2021 / 2020 / 2019 / 2018 / 2017 / 2016 / 2013) / Ricardo recognised as a
top lawyer in the Private Client practice area (2020 / 2019 / 2018 / 2017)
▪ International Tax Review – Ana Rita Pereira included in the Women in Tax Leaders guide (2021 / 2020 / 2019 / 2018 / 2017)
▪ ITR World Tax – Ricardo, Ana Isabel Correia and Ana Rita included in the Tax Controversy Leaders guide (2022 / 2021 / 2020 / 2019 / 2018 / 2017) | RPBA Tier 2
(2021 / 2020 / 2019 / 2018) | RPBA Tier 3 (2017 / 2016 / 2015 / 2014) | RPBA Tier 4 (2013 / 2012 / 2011)
▪ ITR World Transfer Pricing – Ricardo mentioned / RPBA Tier 3 (2022 / 2021 / 2020 / 2019 / 2018 / 2017 / 2016 / 2015 / 2014)
▪ Leaders League – RPBA and Ricardo mentioned as “Excellent” under the "Corporate Tax" practice area (2022 / 2021)
▪ Corporate LiveWire – Ricardo da Palma Borges chosen as the winner of the Finance Award for Tax Lawyer of the Year – Portugal (2017) / Ricardo da Palma Borges
chosen as the winner of the Finance Award for Excellence in Tax Planning – Portugal (2016)
▪ Global Law Experts - RPBA Boutique Tax Law Firm of the Year in Portugal (2017 / 2015) / RPBA Tax Law Firm of the Year in Portugal (2016)
▪ Expert Guides – Ricardo ranked as a top lawyer in the Tax Lawyers directory (2022 / 2021 / 2020 / 2019 / 2018 / 2017 / 2016)
▪ Corporate Intl Magazine Global Award – RPBA Tax Law Firm of the Year – Portugal (2018 / 2017 / 2016 / 2014)
▪ Corporate Intl Magazine Legal Award – RPBA Boutique Tax Law Firm of the Year – Portugal (2015)
▪ Acquisition International Tax Award – RPBA Tax Law Boutique Firm of the Year – Portugal (2015)
▪ Acquisition International Legal Award – RPBA Boutique Law Firm of the Year – Portugal (2014)
▪ Tax Directors Handbook – Ricardo mentioned / RPBA Tier 3 (2015) and Tier 4 (2014) 35
(+351) 212 402 743
geral@rpba.pt
www.rpba.pt
www.linkedin.com/company/rpba
www.slideshare.net/rpba
15

More Related Content

What's hot

Paripatra_2019-20 আয়কর পরিপত্র ২০১৯ - ২০২০
Paripatra_2019-20 আয়কর পরিপত্র ২০১৯ - ২০২০Paripatra_2019-20 আয়কর পরিপত্র ২০১৯ - ২০২০
Paripatra_2019-20 আয়কর পরিপত্র ২০১৯ - ২০২০Sazzad Hossain, ITP, MBA, CSCA™
 
Presentation on GST
Presentation on GSTPresentation on GST
Presentation on GSTJakey Rohira
 
MEANING & OBJECTIVES OF GOVT. BUDGET
MEANING & OBJECTIVES OF GOVT. BUDGET MEANING & OBJECTIVES OF GOVT. BUDGET
MEANING & OBJECTIVES OF GOVT. BUDGET Amritesh Mishra
 
Taxation New
Taxation NewTaxation New
Taxation NewSkulkar3
 
Pagos a cuenta del impuesto a la renta a partir de 2013 juan daniel davila ...
Pagos a cuenta del impuesto a la renta a partir de 2013   juan daniel davila ...Pagos a cuenta del impuesto a la renta a partir de 2013   juan daniel davila ...
Pagos a cuenta del impuesto a la renta a partir de 2013 juan daniel davila ...Juan Daniel Dávila
 
Lezione n. 05 (2 ore) - Gli atti della gestione economico-finanziaria alla lu...
Lezione n. 05 (2 ore) - Gli atti della gestione economico-finanziaria alla lu...Lezione n. 05 (2 ore) - Gli atti della gestione economico-finanziaria alla lu...
Lezione n. 05 (2 ore) - Gli atti della gestione economico-finanziaria alla lu...Simone Chiarelli
 
Lezione n. 06 - Contabilità pubblica (programmazione finanziaria, armonizzazi...
Lezione n. 06 - Contabilità pubblica (programmazione finanziaria, armonizzazi...Lezione n. 06 - Contabilità pubblica (programmazione finanziaria, armonizzazi...
Lezione n. 06 - Contabilità pubblica (programmazione finanziaria, armonizzazi...Simone Chiarelli
 
Value Added Tax (VAT)
Value Added Tax (VAT)Value Added Tax (VAT)
Value Added Tax (VAT)Tasmi Turin
 
Accounting entries under gst
Accounting entries under gstAccounting entries under gst
Accounting entries under gstRathin Mondal
 
DOMESTIC TAXATION V/S INTERNATIONAL TAXATION
DOMESTIC  TAXATION  V/S  INTERNATIONAL  TAXATIONDOMESTIC  TAXATION  V/S  INTERNATIONAL  TAXATION
DOMESTIC TAXATION V/S INTERNATIONAL TAXATIONSundar B N
 

What's hot (20)

RPBA Newsletter: Cross Border Succession - Updated: 21.09.2018
RPBA Newsletter: Cross Border Succession - Updated: 21.09.2018RPBA Newsletter: Cross Border Succession - Updated: 21.09.2018
RPBA Newsletter: Cross Border Succession - Updated: 21.09.2018
 
Mecanismos de comunicação e troca de informações financeiras e fiscais - Actu...
Mecanismos de comunicação e troca de informações financeiras e fiscais - Actu...Mecanismos de comunicação e troca de informações financeiras e fiscais - Actu...
Mecanismos de comunicação e troca de informações financeiras e fiscais - Actu...
 
NHR case-studies Infographics 31.10.2019
NHR case-studies Infographics 31.10.2019NHR case-studies Infographics 31.10.2019
NHR case-studies Infographics 31.10.2019
 
Paripatra_2019-20 আয়কর পরিপত্র ২০১৯ - ২০২০
Paripatra_2019-20 আয়কর পরিপত্র ২০১৯ - ২০২০Paripatra_2019-20 আয়কর পরিপত্র ২০১৯ - ২০২০
Paripatra_2019-20 আয়কর পরিপত্র ২০১৯ - ২০২০
 
PPT on GSTR 9C
PPT on GSTR 9CPPT on GSTR 9C
PPT on GSTR 9C
 
Presentation on GST
Presentation on GSTPresentation on GST
Presentation on GST
 
MEANING & OBJECTIVES OF GOVT. BUDGET
MEANING & OBJECTIVES OF GOVT. BUDGET MEANING & OBJECTIVES OF GOVT. BUDGET
MEANING & OBJECTIVES OF GOVT. BUDGET
 
Taxation New
Taxation NewTaxation New
Taxation New
 
GST PPT.pptx
GST PPT.pptxGST PPT.pptx
GST PPT.pptx
 
Pagos a cuenta del impuesto a la renta a partir de 2013 juan daniel davila ...
Pagos a cuenta del impuesto a la renta a partir de 2013   juan daniel davila ...Pagos a cuenta del impuesto a la renta a partir de 2013   juan daniel davila ...
Pagos a cuenta del impuesto a la renta a partir de 2013 juan daniel davila ...
 
Lezione n. 05 (2 ore) - Gli atti della gestione economico-finanziaria alla lu...
Lezione n. 05 (2 ore) - Gli atti della gestione economico-finanziaria alla lu...Lezione n. 05 (2 ore) - Gli atti della gestione economico-finanziaria alla lu...
Lezione n. 05 (2 ore) - Gli atti della gestione economico-finanziaria alla lu...
 
Lezione n. 06 - Contabilità pubblica (programmazione finanziaria, armonizzazi...
Lezione n. 06 - Contabilità pubblica (programmazione finanziaria, armonizzazi...Lezione n. 06 - Contabilità pubblica (programmazione finanziaria, armonizzazi...
Lezione n. 06 - Contabilità pubblica (programmazione finanziaria, armonizzazi...
 
Diritto tributario
Diritto tributarioDiritto tributario
Diritto tributario
 
Introduction to income tax
Introduction to income tax Introduction to income tax
Introduction to income tax
 
GSTR-9 (ANNUAL RETURN)
GSTR-9 (ANNUAL RETURN)GSTR-9 (ANNUAL RETURN)
GSTR-9 (ANNUAL RETURN)
 
Value Added Tax (VAT)
Value Added Tax (VAT)Value Added Tax (VAT)
Value Added Tax (VAT)
 
Accounting entries under gst
Accounting entries under gstAccounting entries under gst
Accounting entries under gst
 
British exit from European Union 2016
British exit from European Union 2016British exit from European Union 2016
British exit from European Union 2016
 
DOMESTIC TAXATION V/S INTERNATIONAL TAXATION
DOMESTIC  TAXATION  V/S  INTERNATIONAL  TAXATIONDOMESTIC  TAXATION  V/S  INTERNATIONAL  TAXATION
DOMESTIC TAXATION V/S INTERNATIONAL TAXATION
 
Brexit
Brexit   Brexit
Brexit
 

Similar to Portuguese NHR Tax Regime: FAQs & Reasons to Move to Portugal

PORTUGAL a nearshore outsourcing destination
PORTUGAL  a nearshore outsourcing destinationPORTUGAL  a nearshore outsourcing destination
PORTUGAL a nearshore outsourcing destinationCláudio Carneiro
 
Non habitual residents tax regime en 03.2017
Non habitual residents tax regime  en 03.2017Non habitual residents tax regime  en 03.2017
Non habitual residents tax regime en 03.2017Paulo von Hafe
 
20130724 - PR - Icade first half results 2013
20130724 - PR - Icade first half results 201320130724 - PR - Icade first half results 2013
20130724 - PR - Icade first half results 2013ICADE
 
France Business environment
France Business environmentFrance Business environment
France Business environmentSheikh Shahnawaz
 
Portugal Startup Scene Report 2021
Portugal Startup Scene Report 2021Portugal Startup Scene Report 2021
Portugal Startup Scene Report 2021PedroCastelBranco2
 
Regulatory reform in the telecommunication industry in spain
Regulatory reform in the telecommunication industry in spainRegulatory reform in the telecommunication industry in spain
Regulatory reform in the telecommunication industry in spainCMR WORLD TECH
 
2014 05 07 e health forum, athens, herve le guyader presentation on Aquitaine...
2014 05 07 e health forum, athens, herve le guyader presentation on Aquitaine...2014 05 07 e health forum, athens, herve le guyader presentation on Aquitaine...
2014 05 07 e health forum, athens, herve le guyader presentation on Aquitaine...Herve LE GUYADER
 
Expanding your business through exports to the U.S. market
Expanding your business through exports to the U.S. marketExpanding your business through exports to the U.S. market
Expanding your business through exports to the U.S. marketProColombia
 
IBC Madeira - activities and investment
IBC Madeira -  activities and investmentIBC Madeira -  activities and investment
IBC Madeira - activities and investmentNicolas Veiga França
 
EU: Toilet Paper - Market Report. Analysis And Forecast To 2020
EU: Toilet Paper - Market Report. Analysis And Forecast To 2020EU: Toilet Paper - Market Report. Analysis And Forecast To 2020
EU: Toilet Paper - Market Report. Analysis And Forecast To 2020IndexBox Marketing
 
Portugal , country full of opportunities
Portugal , country full of opportunitiesPortugal , country full of opportunities
Portugal , country full of opportunitiesRinkle Kaur
 
EU: Clocks – Market Report. Analysis and Forecast to 2020
EU: Clocks – Market Report. Analysis and Forecast to 2020EU: Clocks – Market Report. Analysis and Forecast to 2020
EU: Clocks – Market Report. Analysis and Forecast to 2020IndexBox Marketing
 

Similar to Portuguese NHR Tax Regime: FAQs & Reasons to Move to Portugal (20)

Portugal: Non Habitual Resident and Madeira Free Zone Regimes – Opportunities...
Portugal: Non Habitual Resident and Madeira Free Zone Regimes – Opportunities...Portugal: Non Habitual Resident and Madeira Free Zone Regimes – Opportunities...
Portugal: Non Habitual Resident and Madeira Free Zone Regimes – Opportunities...
 
PORTUGAL a nearshore outsourcing destination
PORTUGAL  a nearshore outsourcing destinationPORTUGAL  a nearshore outsourcing destination
PORTUGAL a nearshore outsourcing destination
 
Investing in Portugal
Investing in PortugalInvesting in Portugal
Investing in Portugal
 
Non habitual residents tax regime en 03.2017
Non habitual residents tax regime  en 03.2017Non habitual residents tax regime  en 03.2017
Non habitual residents tax regime en 03.2017
 
20130724 - PR - Icade first half results 2013
20130724 - PR - Icade first half results 201320130724 - PR - Icade first half results 2013
20130724 - PR - Icade first half results 2013
 
Workbook - New Deals
Workbook - New DealsWorkbook - New Deals
Workbook - New Deals
 
France Business environment
France Business environmentFrance Business environment
France Business environment
 
Portugal Startup Scene Report 2021
Portugal Startup Scene Report 2021Portugal Startup Scene Report 2021
Portugal Startup Scene Report 2021
 
Regulatory reform in the telecommunication industry in spain
Regulatory reform in the telecommunication industry in spainRegulatory reform in the telecommunication industry in spain
Regulatory reform in the telecommunication industry in spain
 
Contex t report
Contex t reportContex t report
Contex t report
 
Dr. Constantinos Katzis
 Dr. Constantinos Katzis Dr. Constantinos Katzis
Dr. Constantinos Katzis
 
2014 05 07 e health forum, athens, herve le guyader presentation on Aquitaine...
2014 05 07 e health forum, athens, herve le guyader presentation on Aquitaine...2014 05 07 e health forum, athens, herve le guyader presentation on Aquitaine...
2014 05 07 e health forum, athens, herve le guyader presentation on Aquitaine...
 
Expanding your business through exports to the U.S. market
Expanding your business through exports to the U.S. marketExpanding your business through exports to the U.S. market
Expanding your business through exports to the U.S. market
 
Doing business Portugal 2019
Doing business Portugal 2019Doing business Portugal 2019
Doing business Portugal 2019
 
IBC Madeira - activities and investment
IBC Madeira -  activities and investmentIBC Madeira -  activities and investment
IBC Madeira - activities and investment
 
Presentation Carlos Pacheco IX Regional EACD Lisbon Debate 2012
Presentation Carlos Pacheco IX Regional EACD Lisbon Debate 2012Presentation Carlos Pacheco IX Regional EACD Lisbon Debate 2012
Presentation Carlos Pacheco IX Regional EACD Lisbon Debate 2012
 
EU: Toilet Paper - Market Report. Analysis And Forecast To 2020
EU: Toilet Paper - Market Report. Analysis And Forecast To 2020EU: Toilet Paper - Market Report. Analysis And Forecast To 2020
EU: Toilet Paper - Market Report. Analysis And Forecast To 2020
 
Portugal , country full of opportunities
Portugal , country full of opportunitiesPortugal , country full of opportunities
Portugal , country full of opportunities
 
EU: Clocks – Market Report. Analysis and Forecast to 2020
EU: Clocks – Market Report. Analysis and Forecast to 2020EU: Clocks – Market Report. Analysis and Forecast to 2020
EU: Clocks – Market Report. Analysis and Forecast to 2020
 
Living in Portugal- E&V Presentation
Living in Portugal- E&V PresentationLiving in Portugal- E&V Presentation
Living in Portugal- E&V Presentation
 

Recently uploaded

如何办理新加坡南洋理工大学毕业证(本硕)NTU学位证书
如何办理新加坡南洋理工大学毕业证(本硕)NTU学位证书如何办理新加坡南洋理工大学毕业证(本硕)NTU学位证书
如何办理新加坡南洋理工大学毕业证(本硕)NTU学位证书Fir L
 
Good Governance Practices for protection of Human Rights (Discuss Transparen...
Good Governance Practices for protection  of Human Rights (Discuss Transparen...Good Governance Practices for protection  of Human Rights (Discuss Transparen...
Good Governance Practices for protection of Human Rights (Discuss Transparen...shubhuc963
 
如何办理(GWU毕业证书)乔治华盛顿大学毕业证学位证书
如何办理(GWU毕业证书)乔治华盛顿大学毕业证学位证书如何办理(GWU毕业证书)乔治华盛顿大学毕业证学位证书
如何办理(GWU毕业证书)乔治华盛顿大学毕业证学位证书SD DS
 
如何办理(UoM毕业证书)曼彻斯特大学毕业证学位证书
如何办理(UoM毕业证书)曼彻斯特大学毕业证学位证书如何办理(UoM毕业证书)曼彻斯特大学毕业证学位证书
如何办理(UoM毕业证书)曼彻斯特大学毕业证学位证书srst S
 
如何办理(uOttawa毕业证书)渥太华大学毕业证学位证书
如何办理(uOttawa毕业证书)渥太华大学毕业证学位证书如何办理(uOttawa毕业证书)渥太华大学毕业证学位证书
如何办理(uOttawa毕业证书)渥太华大学毕业证学位证书SD DS
 
Constitutional Values & Fundamental Principles of the ConstitutionPPT.pptx
Constitutional Values & Fundamental Principles of the ConstitutionPPT.pptxConstitutional Values & Fundamental Principles of the ConstitutionPPT.pptx
Constitutional Values & Fundamental Principles of the ConstitutionPPT.pptxsrikarna235
 
FINALTRUEENFORCEMENT OF BARANGAY SETTLEMENT.ppt
FINALTRUEENFORCEMENT OF BARANGAY SETTLEMENT.pptFINALTRUEENFORCEMENT OF BARANGAY SETTLEMENT.ppt
FINALTRUEENFORCEMENT OF BARANGAY SETTLEMENT.pptjudeplata
 
如何办理(ISU毕业证书)爱荷华州立大学毕业证学位证书
如何办理(ISU毕业证书)爱荷华州立大学毕业证学位证书如何办理(ISU毕业证书)爱荷华州立大学毕业证学位证书
如何办理(ISU毕业证书)爱荷华州立大学毕业证学位证书SD DS
 
Legal Alert - Vietnam - First draft Decree on mechanisms and policies to enco...
Legal Alert - Vietnam - First draft Decree on mechanisms and policies to enco...Legal Alert - Vietnam - First draft Decree on mechanisms and policies to enco...
Legal Alert - Vietnam - First draft Decree on mechanisms and policies to enco...Dr. Oliver Massmann
 
如何办理密德萨斯大学毕业证(本硕)Middlesex学位证书
如何办理密德萨斯大学毕业证(本硕)Middlesex学位证书如何办理密德萨斯大学毕业证(本硕)Middlesex学位证书
如何办理密德萨斯大学毕业证(本硕)Middlesex学位证书FS LS
 
如何办理(UCD毕业证书)加州大学戴维斯分校毕业证学位证书
如何办理(UCD毕业证书)加州大学戴维斯分校毕业证学位证书如何办理(UCD毕业证书)加州大学戴维斯分校毕业证学位证书
如何办理(UCD毕业证书)加州大学戴维斯分校毕业证学位证书SD DS
 
如何办理(UNK毕业证书)内布拉斯加大学卡尼尔分校毕业证学位证书
如何办理(UNK毕业证书)内布拉斯加大学卡尼尔分校毕业证学位证书如何办理(UNK毕业证书)内布拉斯加大学卡尼尔分校毕业证学位证书
如何办理(UNK毕业证书)内布拉斯加大学卡尼尔分校毕业证学位证书SD DS
 
如何办理佛蒙特大学毕业证学位证书
 如何办理佛蒙特大学毕业证学位证书 如何办理佛蒙特大学毕业证学位证书
如何办理佛蒙特大学毕业证学位证书Fir sss
 
An Introduction guidance of the European Union Law 2020_EU Seminar 4.pptx
An Introduction guidance of the European Union Law 2020_EU Seminar 4.pptxAn Introduction guidance of the European Union Law 2020_EU Seminar 4.pptx
An Introduction guidance of the European Union Law 2020_EU Seminar 4.pptxKUHANARASARATNAM1
 
John Hustaix - The Legal Profession: A History
John Hustaix - The Legal Profession:  A HistoryJohn Hustaix - The Legal Profession:  A History
John Hustaix - The Legal Profession: A HistoryJohn Hustaix
 
VIETNAM – LATEST GUIDE TO CONTRACT MANUFACTURING AND TOLLING AGREEMENTS
VIETNAM – LATEST GUIDE TO CONTRACT MANUFACTURING AND TOLLING AGREEMENTSVIETNAM – LATEST GUIDE TO CONTRACT MANUFACTURING AND TOLLING AGREEMENTS
VIETNAM – LATEST GUIDE TO CONTRACT MANUFACTURING AND TOLLING AGREEMENTSDr. Oliver Massmann
 
如何办理澳洲南澳大学(UniSA)毕业证学位证书
如何办理澳洲南澳大学(UniSA)毕业证学位证书如何办理澳洲南澳大学(UniSA)毕业证学位证书
如何办理澳洲南澳大学(UniSA)毕业证学位证书Fir L
 
Why Every Business Should Invest in a Social Media Fraud Analyst.pdf
Why Every Business Should Invest in a Social Media Fraud Analyst.pdfWhy Every Business Should Invest in a Social Media Fraud Analyst.pdf
Why Every Business Should Invest in a Social Media Fraud Analyst.pdfMilind Agarwal
 
昆士兰科技大学毕业证学位证成绩单-补办步骤澳洲毕业证书
昆士兰科技大学毕业证学位证成绩单-补办步骤澳洲毕业证书昆士兰科技大学毕业证学位证成绩单-补办步骤澳洲毕业证书
昆士兰科技大学毕业证学位证成绩单-补办步骤澳洲毕业证书1k98h0e1
 

Recently uploaded (20)

如何办理新加坡南洋理工大学毕业证(本硕)NTU学位证书
如何办理新加坡南洋理工大学毕业证(本硕)NTU学位证书如何办理新加坡南洋理工大学毕业证(本硕)NTU学位证书
如何办理新加坡南洋理工大学毕业证(本硕)NTU学位证书
 
Good Governance Practices for protection of Human Rights (Discuss Transparen...
Good Governance Practices for protection  of Human Rights (Discuss Transparen...Good Governance Practices for protection  of Human Rights (Discuss Transparen...
Good Governance Practices for protection of Human Rights (Discuss Transparen...
 
如何办理(GWU毕业证书)乔治华盛顿大学毕业证学位证书
如何办理(GWU毕业证书)乔治华盛顿大学毕业证学位证书如何办理(GWU毕业证书)乔治华盛顿大学毕业证学位证书
如何办理(GWU毕业证书)乔治华盛顿大学毕业证学位证书
 
如何办理(UoM毕业证书)曼彻斯特大学毕业证学位证书
如何办理(UoM毕业证书)曼彻斯特大学毕业证学位证书如何办理(UoM毕业证书)曼彻斯特大学毕业证学位证书
如何办理(UoM毕业证书)曼彻斯特大学毕业证学位证书
 
如何办理(uOttawa毕业证书)渥太华大学毕业证学位证书
如何办理(uOttawa毕业证书)渥太华大学毕业证学位证书如何办理(uOttawa毕业证书)渥太华大学毕业证学位证书
如何办理(uOttawa毕业证书)渥太华大学毕业证学位证书
 
Constitutional Values & Fundamental Principles of the ConstitutionPPT.pptx
Constitutional Values & Fundamental Principles of the ConstitutionPPT.pptxConstitutional Values & Fundamental Principles of the ConstitutionPPT.pptx
Constitutional Values & Fundamental Principles of the ConstitutionPPT.pptx
 
FINALTRUEENFORCEMENT OF BARANGAY SETTLEMENT.ppt
FINALTRUEENFORCEMENT OF BARANGAY SETTLEMENT.pptFINALTRUEENFORCEMENT OF BARANGAY SETTLEMENT.ppt
FINALTRUEENFORCEMENT OF BARANGAY SETTLEMENT.ppt
 
如何办理(ISU毕业证书)爱荷华州立大学毕业证学位证书
如何办理(ISU毕业证书)爱荷华州立大学毕业证学位证书如何办理(ISU毕业证书)爱荷华州立大学毕业证学位证书
如何办理(ISU毕业证书)爱荷华州立大学毕业证学位证书
 
Legal Alert - Vietnam - First draft Decree on mechanisms and policies to enco...
Legal Alert - Vietnam - First draft Decree on mechanisms and policies to enco...Legal Alert - Vietnam - First draft Decree on mechanisms and policies to enco...
Legal Alert - Vietnam - First draft Decree on mechanisms and policies to enco...
 
如何办理密德萨斯大学毕业证(本硕)Middlesex学位证书
如何办理密德萨斯大学毕业证(本硕)Middlesex学位证书如何办理密德萨斯大学毕业证(本硕)Middlesex学位证书
如何办理密德萨斯大学毕业证(本硕)Middlesex学位证书
 
如何办理(UCD毕业证书)加州大学戴维斯分校毕业证学位证书
如何办理(UCD毕业证书)加州大学戴维斯分校毕业证学位证书如何办理(UCD毕业证书)加州大学戴维斯分校毕业证学位证书
如何办理(UCD毕业证书)加州大学戴维斯分校毕业证学位证书
 
如何办理(UNK毕业证书)内布拉斯加大学卡尼尔分校毕业证学位证书
如何办理(UNK毕业证书)内布拉斯加大学卡尼尔分校毕业证学位证书如何办理(UNK毕业证书)内布拉斯加大学卡尼尔分校毕业证学位证书
如何办理(UNK毕业证书)内布拉斯加大学卡尼尔分校毕业证学位证书
 
young Call Girls in Pusa Road🔝 9953330565 🔝 escort Service
young Call Girls in  Pusa Road🔝 9953330565 🔝 escort Serviceyoung Call Girls in  Pusa Road🔝 9953330565 🔝 escort Service
young Call Girls in Pusa Road🔝 9953330565 🔝 escort Service
 
如何办理佛蒙特大学毕业证学位证书
 如何办理佛蒙特大学毕业证学位证书 如何办理佛蒙特大学毕业证学位证书
如何办理佛蒙特大学毕业证学位证书
 
An Introduction guidance of the European Union Law 2020_EU Seminar 4.pptx
An Introduction guidance of the European Union Law 2020_EU Seminar 4.pptxAn Introduction guidance of the European Union Law 2020_EU Seminar 4.pptx
An Introduction guidance of the European Union Law 2020_EU Seminar 4.pptx
 
John Hustaix - The Legal Profession: A History
John Hustaix - The Legal Profession:  A HistoryJohn Hustaix - The Legal Profession:  A History
John Hustaix - The Legal Profession: A History
 
VIETNAM – LATEST GUIDE TO CONTRACT MANUFACTURING AND TOLLING AGREEMENTS
VIETNAM – LATEST GUIDE TO CONTRACT MANUFACTURING AND TOLLING AGREEMENTSVIETNAM – LATEST GUIDE TO CONTRACT MANUFACTURING AND TOLLING AGREEMENTS
VIETNAM – LATEST GUIDE TO CONTRACT MANUFACTURING AND TOLLING AGREEMENTS
 
如何办理澳洲南澳大学(UniSA)毕业证学位证书
如何办理澳洲南澳大学(UniSA)毕业证学位证书如何办理澳洲南澳大学(UniSA)毕业证学位证书
如何办理澳洲南澳大学(UniSA)毕业证学位证书
 
Why Every Business Should Invest in a Social Media Fraud Analyst.pdf
Why Every Business Should Invest in a Social Media Fraud Analyst.pdfWhy Every Business Should Invest in a Social Media Fraud Analyst.pdf
Why Every Business Should Invest in a Social Media Fraud Analyst.pdf
 
昆士兰科技大学毕业证学位证成绩单-补办步骤澳洲毕业证书
昆士兰科技大学毕业证学位证成绩单-补办步骤澳洲毕业证书昆士兰科技大学毕业证学位证成绩单-补办步骤澳洲毕业证书
昆士兰科技大学毕业证学位证成绩单-补办步骤澳洲毕业证书
 

Portuguese NHR Tax Regime: FAQs & Reasons to Move to Portugal

  • 1. THE PORTUGUESE NON-HABITUAL TAX RESIDENT (NHR) REGIME Frequently Asked Questions & Reasons to Move to Portugal
  • 2. Introduction There are a few things you should know If you are considering moving to Portugal. This updated presentation answers the most frequently asked questions on the Portuguese Non- Habitual Tax Resident regime and provides some reasons why Portugal is a great country to live.
  • 3. 3 29th country on the OECD Better Life Index 2020 (1), 1st on InterNations Expat Insider 2022: Quality of Life Index. (2) According to the 2021 Annual Global Retirement Index from International Living Portugal was considered the best country in Europe to retire to and the 5th best in the World (3) and as reported by CNBC, Portugal is the best place to retire abroad. (4) Portugal (https://en.wikipedia.org/wiki/Portugal) has a number of attractive characteristics: #01 Quality of Life Why Portugal? (1) - https://www.oecdbetterlifeindex.org/countries/portugal/ (2) - https://cms-internationsgmbh.netdna-ssl.com/cdn/file/cms-media/public/2022-07/Expat-Insider-2022-Survey.pdf (3) - https://internationalliving.com/the-best-places-to-retire/ (4) - https://www.cnbc.com/2020/01/03/the-10-best-places-to-retire-abroad.html
  • 4. The non-habitual tax resident (NHR) is a tax regime created to improve Portuguese international competitiveness. This regime targets non- resident individuals who are likely to establish a permanent or a temporary residence in Portugal. The NHR regime establishes, under certain conditions, IRS exemptions on foreign source income, as well as a limited 20% taxation of income from employment and independent personal services, in both cases if deriving from listed high value-added activities. Entrants in the regime since 1 April 2020 are liable to a 10% tax rate on pension income, instead of the previous exemption. FAQ #2 What are the benefits of the NHR regime? FAQ #1 What is the NHR regime? Frequently Asked Questions 4
  • 5. 5 Weather and environment quality (12th country on the OECD 2020 Better Life Index). Why Portugal? Estimated 3300 hours of sunshine per year, one of the highest rates in Europe. #02 Weather #03 Sunshine
  • 6. ▪ Foreign-sourced passive income (interest, dividends, certain royalties, other income from capital, capital gains and income from immovable property) derived by NHR is exempt (without progression except in the case of capital gains on real estate) in Portugal, provided that it is potentially liable to taxation in the source State (i) under the rules of an existing Double Tax Treaty (DTT) or (ii) in the absence thereof, under the rules of the OECD Model Tax Convention if such income is not deemed to arise from a State, region or territory included in the Portuguese tax havens’ blacklist nor from a Portuguese source under the IRS Code territoriality rules. ▪ Foreign-sourced income from pensions is liable to a 10% rate for Portuguese tax residents as from 1 April 2020. Before that, pensions were IRS exempt (with progression) if not deemed to arise from a Portuguese source under the IRS Code territoriality rules. ▪ Foreign-sourced employment income is IRS exempt (with progression), provided that it is effectively taxed in the source State (i) under the rules of a DTT or in, the absence thereof, (ii) of the OECD Model Tax Convention, as long as such income is not deemed to arise from a Portuguese source under the IRS Code territoriality rules. ▪ Foreign-sourced employment income is IRS exempt (without progression) in Portugal, provided that it is income derived from high value- added activities of a scientific, artistic or technical nature and it is effectively taxed in the source State (i) under the rules of a DTT or in, the absence thereof, (ii) of the OECD Model Tax Convention, as long as such income is not deemed to arise from a Portuguese source under the IRS Code territoriality rules. ▪ Foreign-sourced income from independent personal services is IRS exempt (without progression) in Portugal, provided that it derives from high value-added activities of a scientific, artistic or technical nature, as defined by Ministerial Order, and is potentially liable to taxation in the source State (i) under the rules of an existing DTT or (ii) in the absence thereof, under the rules of the OECD Model Tax Convention, if such income is not deemed to arise from a State, region or territory included in the Portuguese tax havens’ blacklist nor from a Portuguese source under the IRS Code territoriality rules. FAQ #3 What types of income are eligible for exemption under NHR regime? Frequently Asked Questions 6
  • 7. 7 Modern and cosmopolitan country: Lisbon was elected one of the best places to travel in 2018 (5) and Porto is the best European city to live in 2019. (6) Lisbon was also ranked the 10th most livable city in the world in Monocle Quality of Life Survey 2019: Best Cities to Live (7) and Braga has earned 1st place on European’s best destinations in 2021. (8) Portugal has a great list of “wonders” declared a World Heritage Site by Unesco. (9) Fado (the Portuguese most traditional music genre) was considered by UNESCO Intangible Cultural Heritage of Humanity, in 2011. #05 Cultural Offering #04 Modernity Why Portugal? (5) - www.europeanbestdestinations.com/european-best-destinations-2018/ (6) - https://www.europeanbestdestinations.com/best-of-europe/best-destinations-to-live-in-europe-if-you-want-to-leave-the-usa/ (7) - https://monocle.com/magazine/issues/125/quality-of-life-survey/ (8) - https://www.europeanbestdestinations.com/european-best-destinations-2021/ (9) - https://en.wikipedia.org/wiki/List_of_World_Heritage_sites_in_Portugal
  • 8. Frequently Asked Questions FAQ #4 What types of income are eligible for reduced rates under NHR regime? Income deriving from employment or independent personal services of a domestic or foreign source but not qualifying for the mentioned exemptions will be liable to autonomous taxation at a special 20% flat rate and not to the general and progressive IRS rates (currently of up to 53% for yearly taxable income above € 250.000), provided that it derives from high value-added activities of a scientific, artistic or technical nature. Entrants in the regime that became Portuguese tax resident as from 1 April 2020 are liable to a 10% tax rate on pension income. 8
  • 9. Frequently Asked Questions An amendment to the list of High Value-Added Activities, applicable from 1 January 2020 onwards, was published on 23 July 2019 (Ministerial Order nr. 230/2019). This was an in-depth revision of the list of activities that has been in effect since 2010, in order to align them with the needs of the labour market. Nevertheless, the most recent Ministerial Order encompasses a wide range of professions and activities according to the Portuguese Classification of Professions (PCP), which allows for more immediate clarification of interpretive doubts regarding the scope and range of each of the activities listed in the table. This new list entered into force on 1 January 2020 and applies to individuals registered under the NHR regime from 2020 onwards. For NHR registered as such with effect up to 31 December 2019, even if their registration took place in 2020, the old list still applies. However, these “old entrants” can also opt to benefit from the new one. FAQ #5 What are considered high value-added activities of a scientific, artistic or technical nature? 9
  • 10. New list of High Value-Added Activities of a Scientific, Artistic or Technical Nature (Ministerial Order nr. 230/2019, of 23 July) I – Professional activities (PCP codes): 112 — General manager and executive manager 12 — Manager of administrative and commercial services (v.g., financial, human resources, and strategy) 13 — Production and specialized services’ managers (v.g., farming, livestock, forestry, fishery, mining industry, transports and others 14 — Managers of hotel business, restaurants/catering, trade and other services 21 —Experts in physics, mathematics, engineering and similar technics (v.g., chemistry, statistics, urban planning, and others) 221 — Doctors (v.g., generalists and experts) 2261 — Dentists and stomatologists 231 — University and higher education professors 25 — IT and communication experts (v.g., software apps, web, etc.) 264 — Authors, journalists and linguists 265 — Creative artists and performing artists (v.g., musicians, cinema producers, actors, dancers, etc.) 31 — Technicians as well as science and engineering professions of intermediate level (v.g., mining industry, life sciences and others) 35 — Technicians of information and communication technologies (v.g., telecommunications and radio) 61 — Farmers and market-oriented skilled agriculture and livestock production workers 62 — Market-oriented skilled forestry, fishery and hunting workers 7 — Skilled industry, construction and crafts workers, including skilled workers of metalwork, food processing, woodwork, clothing, handicraft, printing, manufacture of precision instruments, jewelers, artisans, electricians and electronics professionals 8 — Facility and machinery operators and assembly workers, namely operators of fixed installations and machinery 10
  • 11. Professionals' workers included in the above-mentioned professional activities shall possess at least, a level 4 of the European Qualifications Framework or Level 35 of International Standard Classification of Education, or five years of duly proven professional experience. II – Other professional activities: Directors and managers of companies carrying out productive investment activities may also benefit to the extent that they are engaged in the projects for which contractual tax benefits have been granted under the Investment Taxation Code (Código Fiscal do Investimento) enacted by Decree-Law nr. 162/2014, of 31 October 2014. 11 New list of High Value-Added Activities of a Scientific, Artistic or Technical Nature (Ministerial Order nr. 230/2019, of 23 July)
  • 12. 1 - Architects, engineers and similar technicians: 101 – Architects 102 – Engineers 103 – Geologists 2 - Visual artists, actors and musicians: 201 – Theater, ballet, film, radio and television Artists 202 – Singers 203 – Sculptors 204 – Musicians 205 – Painters 3 - Auditors: 301 – Auditors 302 – Tax Consultants 4 - Doctors and dentists: 401 – Dentists 402 – Analyst Doctors 403 – Surgeons 404 – Board doctors in ships 405 – General Practitioners 406 – Dentists 407 – Dentist Doctors 408 – Physiatrists 12 Old list of High Value-Added Activities of a Scientific, Artistic or Technical Nature (Ministerial Order nr. 12/2010, of 7 January)
  • 13. 6 - Psychologists: 601 – Psychologists 5 - Teachers: 501 – University professors 409 – Gastroenterologists 410 – Ophthalmologists 411 – Orthopedists 412 – Otorhinolaryngologists 413 – Paediatricians 414 – Radiologists 415 – Doctors in other specialties 7 - Professional services, technicians and similar: 701 – Archaeologists 702 – Biologists and experts in life sciences 703 – Computer Programmers 704 – Consulting and computer programming and activities related to information and computer technology 705 – Computer programming activities 706 – Computer consultancy activities 707 – Management and operation of computer equipment 708 – Activities of information services 709 – Activities of data processing, hosting information and related activities/Web portals 710 – Activities of data processing, hosting information and related activities 711 – Other information service activities 712 – Activities of news agencies 713 – Other information service activities 714 – Scientific research and development 715 – Research and development of science physical and natural 716 – Research and development in biotechnology 717 – Designers 8 - Investors, administrators and managers: 801 – Investors, administrators and managers of companies promoting productive investment, if allocated to eligible projects under tax benefits contracts awarded under the Tax Code for Investment, approved by Decree- Law nr. 249/2009, of 23 September 802 – Senior employees of companies 13 Old list of High Value-Added Activities of a Scientific, Artistic or Technical Nature (Ministerial Order nr. 12/2010, of 7 January)
  • 14. 14 The Portuguese gastronomy is as rich and diverse as its heritage and landscapes and has recently been internationally recognised with 33 Michelin star restaurants, totaling 34 stars, in 2022. (10) Portugal is also one of the best wine tourism destinations. Our country had 675 prizes at the 2022’s Decanter World Wines Awards (DWWA) (11) and also achieved 296 Medals in the 2022’s Concours Mondial de Bruxelles. (12) #06 Gastronomy Why Portugal? (10) - https://guide.michelin.com/pt/pt_PT/article/news-and-views/novidades-guia-michelin-portugal-2022 (11) - https://awards.decanter.com/DWWA/2022/ (12) - http://results.concoursmondial.com/index.php
  • 15. (13) - https://universitas21.com/sites/default/files/2020- 04/U21_Rankings%20Report_0320_Final_LR%20Single.pdf (14) - www.ef.edu.pt/epi/regions/europe/portugal/ 15 A large part of the population speaks foreign languages, especially English, Spanish and French. Portugal was ranked 7th out of 112 countries in the EF Global English Proficiency Index 2022. (14) There is a significant number of International Schools throughout Portugal, attended by both Portuguese and foreign students. Portugal is ranked as the 25th best in the World according to the 2020 U21 Ranking of National Higher Education Systems. (13) #08 Other Languages Spoken #07 Education Why Portugal?
  • 16. Frequently Asked Questions 16 Individuals who become resident for tax purposes in Portugal without having been so in the previous five years. ▪ Staying for more than 183 days in the Portuguese territory, whether these days are consecutive or not, in any 12-month period beginning or ending in a given tax year; ▪ If staying for a shorter period, having in the Portuguese territory, on any day of the period referred above, a dwelling under circumstances that lead to the presumption of an intention to hold and occupy it as a place of habitual abode; ▪ Being, on 31 December, a crew member of a ship or aircraft at the service of an entity with residence, head office or effective management in Portugal. FAQ #7 How do I acquire tax residence in Portugal? FAQ #6 Who may apply for the NHR regime?
  • 17. Frequently Asked Questions 17 Registering as a tax resident in Portugal is a requirement to obtain the non-habitual resident status, which means that those wishing to apply for the regime generally must: i. register as non-resident taxpayers; ii. obtain residence permits (for non-EU nationals) and residence certificates (for EU nationals); iii. register as tax residents; and iv. only then apply for the non-habitual resident status. FAQ #8 What is the procedure to register as tax resident in Portugal?
  • 18. 18 About 300 daily flights from Portugal to foreign countries. Porto Airport ranks among the best airports in Europe since 2006. (15) Portugal ranked 16th among 117 countries in the 2021 WEF Travel & Tourism Competitiveness Index. (16) #09 Daily Flights #10 Convenient Location for Globetrotters Why Portugal? (15) - https://aci.aero/programs-and-services/asq/asq-awards-and-recognition/ (16) - https://www3.weforum.org/docs/WEF_Travel_Tourism_Development_2021.pdf
  • 19. 19 Top conditions for sports (sailing, diving, biking, trekking, horse riding, golf - with some of the best World courses (17)). #11 Sports Why Portugal? (17) - https://worldgolfawards.com/award/world-best-golf-destination/2018 https://worldgolfawards.com/award/world-best-golf-destination/2017 https://worldgolfawards.com/award/world-best-golf-destination/2016 https://worldgolfawards.com/award/world-best-golf-destination/2015 https://worldgolfawards.com/award/world-best-golf-destination/2014
  • 20. Frequently Asked Questions 20 Non-habitual resident individuals may enjoy such status for a ten-year period, after which they will be taxed under the standard IRS regime. FAQ #10 For how long may I enjoy the NHR status? An application must be submitted until 31 March of the tax year following that in which Portuguese tax residence is acquired. From 2 August 2016 onwards, the applications must be submitted on the tax authorities’ website. Moreover, individuals must submit a statement whereby they solemnly declare that they have not fulfilled the criteria necessary for being considered a Portuguese tax resident during the preceding five years. FAQ #9 How do I apply for the NHR status? After obtaining the non-habitual resident status it will be necessary to file annual tax returns in Portugal, stating the worldwide income and expenses, for which adequate documentation keeping is required. FAQ #11 Once I have the NHR status, what are my tax obligations?
  • 21. (18) - https://www.numbeo.com/cost-of-living/country_result.jsp?country=Portugal 21 Value for money in real estate investments (which have undergone significant decreases from 2008 to 2015). In comparison with other major European countries, Portugal is highly affordable. (18) #12 Investments #13 Cost of Living Why Portugal?
  • 22. Frequently Asked Questions 22 The NHR status is granted for a ten-year period. The particular features of the NHR regime may always be amended by law, for better or for worse, even for those who have been granted NHR status prior to the enactment of any change (although in such cases the degree of change to the regime which is admissible under Portuguese constitutional law is very debatable). The State Budget Law for 2020 introduced a 10% tax rate on pension income for new entrants in the regime that became Portuguese tax resident as from 1 April 2020. Old entrants into the NHR regime (those that became Portuguese tax residents before 1 April 2020) were grandfathered from the changes promoted by the State Budget Law for 2020 and remain in the old regime (although, in practice, they have an annual opting out towards the new regime). This is a very important precedent that shows the political willingness to safeguard the legitimate expectations of taxpayers. Indeed, those that entered the regime prior to the State Budget Law for 2020 changes kept and will keep the previous regime until the end of their 10-year tax benefit period. This regime was implemented in 2009 by a Socialist (center-left wing) government and has remained stable since then. The current Socialist Government (with parliamentary majority until October 2026), the previous Socialist Government of 2015-2019 and the previous 2011-2015 government coalition of Social Democrats party and Christian Democrat / People’s party (center-right wing) have not materially changed the regime. The general perception is of its acceptance by the community in general and by the main political parties. The only relevant adverse change to the regime, prior to 2020, was the enforcement in 2011 and from 2013 to 2017 of a 3,5% surcharge to employment or independent personal services income deriving from high value added activities of a scientific, artistic or technical nature obtained by NHR residents liable to autonomous taxation at a special 20% flat rate. FAQ #12 For how long are the benefits of the regime granted and have they changed?
  • 23. Frequently Asked Questions 23 A new change to the NHR regime could happen, but it is not likely, as the regime was introduced in 2009 by a government of the same center-left wing party (“Partido Socialista”) as the present government, which has parliamentary majority until October 2026. Additionally, there is currently no significant public debate or controversy surrounding the NHR regime. In any case, if such change happens: i. Even if NHR status is abolished, it cannot be taken away from those that already have it at the time the change is approved; ii. Although the NHR status cannot be taken away, the regime could be made less attractive (reducing the scope of the exemptions, for instance) even for those that have obtained it in the past. To what extent such change could be made is very debatable under Portuguese administrative and constitutional law. Some changes would always be admissible, but in principle a change that would make the NHR regime purely nominal (making NHR and normal residents taxed in the same way or with only very minor differences) should not be allowed. Assessing the degree of change that is allowed is very difficult. FAQ #13 Can the NHR regime change again?
  • 24. (19) - https://www.pordata.pt/en/Europe/Life+expectancy+at+birth+total+and+by+sex-1260 24 Portugal has a high quality health system, offering both public and private healthcare. According to PORDATA data base, the average life expectancy at birth in Portugal in 2021 was 81,2 years. (19) #14 Health System Why Portugal?
  • 25. Frequently Asked Questions 25 Firstly, the likelihood of a unilateral termination of an existing DTT is very reduced. A renegotiation of DTTs between Portugal and other States is currently an issue with two Nordic countries, and is driven by the double non-taxation of private pensions allowed by the combination of the NHR regime with DTTs following the OECD Model Tax Convention. However, recently, Finland and Sweden terminated the DTT with Portugal. Its application ceased since the start of 2019 and 2022, respectively. There is no longer a restriction on these countries’ right to tax private pensions received in those countries by NHR. These developments motivated Portugal to unilaterally change its domestic NHR regime in 2020, starting to impose tax on foreign-sourced pension income for entrants into it that became Portuguese tax resident as from 1 April 2020. Currently, no other States have publicly signaled a will to revise their DTTs with Portugal due to the NHR regime but we are aware that some negotiations in this regard are taking place with France and Germany. FAQ #14 How does the termination or renegotiation of a double tax treaty (DTT) between Portugal, as my residence State, and an income source State, affect the NHR regime?
  • 26. 26 Successful conclusion of the Troika’s (International Monetary Fund, European Central Bank and EU) financial assistance program (2011-2014) on May 17, 2014. Portugal is a developed democracy with political and social stability and was ranked among the countries with the most freedom according to the Freedom of the World 2022 Report. (20) Portugal was also ranked 7th out of 179 countries in the 2020 Democracy Report (21) and was ranked 28th out of 167 countries in the 2021 Economist Intelligence Unit's Democracy Index. (22) #16 Economic Progress #15 Political Stability Why Portugal? (20) - https://freedomhouse.org/country/portugal/freedom-world/2022 (21) - www.v-dem.net/media/filer_public/f0/5d/f05d46d8-626f-4b20-8e4e-53d4b134bfcb/democracy_report_2020_low.pdf (22) - https://en.wikipedia.org/wiki/Democracy_Index
  • 27. Frequently Asked Questions 27 FAQ #15 Am I required to provide proof of Portuguese tax residence? As explained in FAQ #7 above there is more than one way to acquire Portuguese tax residence. The 184-day rule is not mandatory as long as one has, in the Portuguese territory, a dwelling under circumstances that lead to the presumption of an intention to hold and occupy it as a place of habitual abode. The Portuguese tax residence, in principle, will not be challenged by the Portuguese Tax Authorities. However, it could be challenged by an income source State, especially if one spends time in that State. In this regard, a number of precautions are advisable: a) keeping a calendar that tracks one’s days of stay in Portugal and in other countries; b) avoiding short-term rentals and frequent address changes within the Portuguese territory from the moment one becomes a tax resident herein; c) ask for invoices with the Portuguese tax number (NIF) on a recurring basis when one acquires products/services in Portugal. The latter will allow the individual (i) to better prove his/her effective presence in Portugal, if challenged, (ii) to benefit from certain deductions on the Portuguese tax assessment, if he/she has taxable income at standard tax rates, and (iii) also make him/her eligible for a State lottery!
  • 28. Frequently Asked Questions 28 In November 2015, the Socialist party, with the parliamentary support of three far-left parties (the Left Block, the Communist and the Green parties) formed a new government. The Socialist party proposed in its electoral program the reintroduction of inheritance taxation between spouses and direct line descendants for “high value” estates (in principle those with a taxable value above 1 million Euros, with a rate of 28% applying to the surplus), but “taking into account the need to avoid phenomena of multiple inheritance taxation”. It was therefore possible that a mild form of inheritance taxation might be re-introduced in Portugal, but it is not clear how it would target NHR with non-Portuguese assets, due to the caveat in commas. Currently, inheritance between direct family is tax exempt, assets outside Portugal are not taxable and when tax is due on Portuguese assets it is so at a low rate - 10%. The Government Program of 2015 intended to tax those exempt cases (most notably those of inheritances between direct family). However, the relevant aspects remained fully uncertain (for instance, if foreign assets would be taxed or not, if donations would be taxed in the same way as inheritances or not, how should the € 1.000.000 be valued, etc.). The 2015-2019 legislature went by and the Government apparently gave up on the idea of amending inheritance taxation. The Socialist party electoral program of 2019 and 2022 and the Socialist government programs for the legislatures of 2019-2023 and 2022-2026 have no mention whatsoever to changes in inheritance taxation. Nevertheless, developments on this issue should be monitored. FAQ #16 What about Gift and Inheritance Taxation in Portugal?
  • 29. (23) - https://www.visionofhumanity.org/wp-content/uploads/2022/06/GPI-2022-web.pdf 29 According to the 2022′s Global Peace Index, Portugal ranks 6th, out of 163 countries. (23) #17 Peaceful Country Why Portugal?
  • 30. (24) - https://www.passportindex.org/byRank.php (25) - https://nationalityindex.com/# 30 If one of the heads of the household qualifies for residency in Portugal, all the dependents will automatically qualify. Moreover, Portugal has one of the world's most valuable passports (24) and the Portuguese citizenship was ranked as the 13th most valuable in the World by Quality of Nationality Index 2018 (QNI). (25) #18 Portuguese Passport / Citizenship Why Portugal?
  • 31. 31 Portugal is an increasingly sought tourist destination. In 2015, it collected 16 awards in the World Travel Awards for Europe. In 2016, Portugal outdid itself and beat its own record: 24 awards in the so- called “Oscars” of European tourism. For the 5th time in the last six years, Portugal was voted as the “Europe's Leading Destination” at those Awards, proving the internationally recognised dynamism, quality and consistency of tourism in the country. (26) #19 Tourism Why Portugal? (26) - www.worldtravelawards.com/winners/2022/europe www.worldtravelawards.com/winners/2018/europe www.worldtravelawards.com/winners/2021/europe www.worldtravelawards.com/winners/2017/europe www.worldtravelawards.com/winners/2020/europe www.worldtravelawards.com/winners/2016/europe www.worldtravelawards.com/winners/2019/europe www.worldtravelawards.com/winners/2015/europe
  • 32. The Portuguese NHR Regime For more information on our Residence Planning Services, please visit our microsite www.nonhabitualtaxresident.com or scan the below QR code with your smartphone: Should you require further information on this issue please check our Information Note on this subject, available at https://www.slideshare.net/RPBA/rpba-newsletter-the- portuguese-nonhabitual-tax-resident-regime-253546943 32
  • 33. Proper legal advice is recommended before any decision is taken to become a Portuguese tax resident, and more so if one wishes to take full advantage from the NHR status. RPBA has an in-depth knowledge and expertise on this regime. To obtain our professional fees or to book a consultation please e-mail us (Marta Rêgo): marta.rego@rpba.pt 33 The Portuguese NHR Regime
  • 34. General warning, disclaimer, copyright and authorised use ▪ In the preparation of this presentation, every effort has been made to offer current, correct and clearly expressed information. However, the said information is intended to afford general guidelines only. This presentation reflects information current at 11 November 2022. ▪ This presentation is distributed with the understanding that RICARDO da PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. is not responsible for the result of any actions taken on the basis of information herein included, nor for any errors or omissions contained herein. ▪ RICARDO da PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. is not attempting through this work to render legal or tax advice and the information in this presentation should be used as a research tool only, and not in lieu of individual professional study with respect to client legal matters. ▪ Portuguese domestic legislation, foreign legislation, EU Directives and tax treaties have anti-abuse provisions, and each client structure should be analysed taking those into account. ▪ RICARDO da PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. is the copyright owner of this presentation and hereby grants you a non-exclusive, non-transferable license to use this presentation provided that you do not modify its content in any way, that you keep its proprietary notices of RICARDO da PALMA BORGES & ASSOCIADOS, SOCIEDADE DE ADVOGADOS, S.P., R.L. and that you do not retain any copyright or other proprietary notices displayed on such content. 34
  • 35. Recent Tax Recognition ▪ Chambers & Partners – Ricardo Band 1 / RPBA Band 3 (2022 / 2021) | Ricardo Band 2 / RPBA Band 3 (2020 / 2019 / 2018 / 2017 / 2016) | Ricardo Band 1 / RPBA Band 3 (2015 / 2014 / 2013) | Ricardo highlighted in Band 1 in the Private Wealth Law practice area of the High Net Worth (HNW) guide (2021 / 2020 / 2019 / 2018) ▪ Legal 500 – Ricardo, Ana Isabel and Rita are Recommended Lawyers / RPBA Band 2 (2022 / 2021 / 2020 / 2019 / 2018) | RPBA Band 3 (2017 / 2016 / 2015 / 2014 / 2013) ▪ Best Lawyers – Ricardo recognised as "Tax Law Lawyer of the Year” (2017) and ranked under the "Tax Law" practice area and the "Tax Planning" subspecialty (2022 / 2021 / 2020 / 2029 / 2018 / 2017 / 2016 / 2015 / 2014 / 2013 / 2012 / 2011) | Ana Isabel Correia recognised as "Tax Law Lawyer of the Year” (2020) and ranked under the "Tax Law" practice area (2022 / 2021 / 2020 /2019) / RPBA Tax Law Firm of the Year in Portugal (2020) ▪ Who’s Who Legal – Ricardo ranked as a top lawyer in the Corporate Tax Lawyers directory (2021 / 2020 / 2019 / 2018 / 2017 / 2016 / 2013) / Ricardo recognised as a top lawyer in the Private Client practice area (2020 / 2019 / 2018 / 2017) ▪ International Tax Review – Ana Rita Pereira included in the Women in Tax Leaders guide (2021 / 2020 / 2019 / 2018 / 2017) ▪ ITR World Tax – Ricardo, Ana Isabel Correia and Ana Rita included in the Tax Controversy Leaders guide (2022 / 2021 / 2020 / 2019 / 2018 / 2017) | RPBA Tier 2 (2021 / 2020 / 2019 / 2018) | RPBA Tier 3 (2017 / 2016 / 2015 / 2014) | RPBA Tier 4 (2013 / 2012 / 2011) ▪ ITR World Transfer Pricing – Ricardo mentioned / RPBA Tier 3 (2022 / 2021 / 2020 / 2019 / 2018 / 2017 / 2016 / 2015 / 2014) ▪ Leaders League – RPBA and Ricardo mentioned as “Excellent” under the "Corporate Tax" practice area (2022 / 2021) ▪ Corporate LiveWire – Ricardo da Palma Borges chosen as the winner of the Finance Award for Tax Lawyer of the Year – Portugal (2017) / Ricardo da Palma Borges chosen as the winner of the Finance Award for Excellence in Tax Planning – Portugal (2016) ▪ Global Law Experts - RPBA Boutique Tax Law Firm of the Year in Portugal (2017 / 2015) / RPBA Tax Law Firm of the Year in Portugal (2016) ▪ Expert Guides – Ricardo ranked as a top lawyer in the Tax Lawyers directory (2022 / 2021 / 2020 / 2019 / 2018 / 2017 / 2016) ▪ Corporate Intl Magazine Global Award – RPBA Tax Law Firm of the Year – Portugal (2018 / 2017 / 2016 / 2014) ▪ Corporate Intl Magazine Legal Award – RPBA Boutique Tax Law Firm of the Year – Portugal (2015) ▪ Acquisition International Tax Award – RPBA Tax Law Boutique Firm of the Year – Portugal (2015) ▪ Acquisition International Legal Award – RPBA Boutique Law Firm of the Year – Portugal (2014) ▪ Tax Directors Handbook – Ricardo mentioned / RPBA Tier 3 (2015) and Tier 4 (2014) 35
  • 36. (+351) 212 402 743 geral@rpba.pt www.rpba.pt www.linkedin.com/company/rpba www.slideshare.net/rpba 15