The Portuguese tax regime for non-habitual residents (NHR) is motivating high net worth individuals, pensioners and high value added professionals like digital nomads to relocate to Portugal, either on a permanent or on a temporary and expatriate basis. The regime is granted to individuals who become resident for tax purposes in Portugal without having been so in the five years preceding its acquisition. Non-habitual resident individuals may enjoy such status for a ten-year period, after which they will be taxed under the standard regime. This regime may grant an exemption on foreign source income as well as a limited taxation on Portuguese domestic source income deriving from high value added activities. Entrants into the NHR regime that became Portuguese tax residents after April 1st 2020 are subject to a flat tax rate of 10% on foreign-sourced pensions (instead of the previous exemption), as well as on other payments, such as pre-retirement benefits and "lump-sum" payments from pension funds and similar retirement schemes. With effect as from January 1st, 2022, Sweden - following the precedent of Finland - terminated its tax treaty with Portugal. RPBA has revised, updated and developed its newsletter, explaining this regime in great detail.

1. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
1
Decree-Law nr.
249/2009, of
September 23,
created a new
Personal Income Tax
regime for NHR
individuals.
A. The non-habitual tax resident
regime
1. The Decree-Law
Decree-Law nr. 249/2009, of
September 23, among other
measures directed at improving
Portuguese international
competitiveness, such as the
approval of the Tax Code for
Investment (“Código Fiscal do
Investimento”), created a new
Personal Income Tax (“Imposto
sobre o Rendimento das Pessoas
Singulares”, hereinafter “IRS”)
regime for NHR individuals.
This status would apparently be
granted to individuals who became
resident for tax purposes in
Portugal starting from January 1,
2009 without having been so in the
five years preceding its acquisition.
NHR individuals may enjoy such
status for a ten-year period, after
which they will be taxed under the
standard IRS regime.
Portuguese tax residence for IRS
purposes, in each tax year, may be
acquired via different ways, such
as:
a) 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 the given tax year;
b) If staying for a shorter period,
having in the Portuguese
territory, on any day during 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; or
c) Being, on December 31, a crew
member of a ship or aircraft at
the service of an entity with
The Portuguese Non-Habitual
Tax Resident (NHR) Regime
October 2022
(recent changes in yellow)

2. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
2
residence, head office or
effective management in
Portugal.
The new tax regime targets non-
resident individuals who are likely
to establish a permanent or a
temporary residence in Portugal.
The regime includes three different
sets of rules, (i) one of them
applicable to foreign-sourced
passive income (interest,
dividends, certain royalties, other
income from capital, capital gains
and income from immovable
property), similar to non-
domiciled taxation regimes such as
the ones of the United Kingdom
and Switzerland, (ii) another
applicable to pensions and (iii) the
remaining to active income, in this
case encompassing income derived
both from foreign and domestic
sources, following expatriate,
rectius impatriate, taxation regimes
such as the ones existing in Spain
and France.
Under the first set of rules, passive
income derived by NHR residents
will be IRS exempt (without
progression except in the cases of
(i) capital gains on real estate and
(ii) when the taxpayer opts via the
Portuguese tax return to aggregate
such income to other income
subject to progressive tax rates,
where the income, although
maintaining its exemption under
the NHR regime - even in (ii) cases,
according to our opinion and to the
tax assessments that we have seen
by the Portuguese Tax Authority -,
must be considered to determine
the tax rates applicable to non-
exempt income). This IRS
exemption applies provided that
the income may be taxed in the
source State under the rules of a tax
treaty entered into by Portugal or,
if no treaty exists, that (i) it may be
The new tax regime
targets non-resident
individuals who are
likely to establish a
permanent or a
temporary residence
in Portugal.

3. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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The passive income
included in this
regime comprises
interest, dividends,
certain royalties,
other income from
capital, capital gains
and income from
immovable property.
taxed in the source State according
to the rules of the OECD Model Tax
Convention on Income and on
Capital, as interpreted in the light
of the Portuguese reservations on
its articles and of the observations
on its commentary; (ii) it is not
considered to arise from a
Portuguese source under the IRS
Code territoriality rules; and (iii)
the source State, region or territory
is not included in the Portuguese
tax havens’ blacklist.
The regime requires only a
potential liability to taxation in the
source State under the rules of a tax
treaty or of the OECD Model Tax
Convention, no effective taxation
being thus required.
The second set of rules relates to
pension income. For those that
became Portuguese tax residents
after the 2020 State Budget Law
entered into force, i.e. after April 1,
2020, a flat tax rate of 10% will
apply to their foreign-sourced
pensions as well as to other
payments, such as pre-retirement
benefits and "lump-sum" payments
from pension funds and similar
retirement schemes. A foreign tax
credit is available for the one paid
on this income at the source State.
Taxpayers may opt out of the 10%
standalone rate and aggregate the
pension income to the general one
liable to the progressive rates. Old
entrants into the NHR regime
(those that became Portuguese tax
residents before April 1, 2020, and
applied in due time, for the
registration as NHR) were
grandfathered from the changes
promoted by the 2020 Budget Law
and remain in the old regime.
Under the blackletter of the law,
there was an opting out towards
the new regime, to be exercised
with the filing of the tax return for
the 2020 income, which occurred
until June 2021. However, in

4. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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practice, the IRS return vis-à-vis the
2021 income again allowed old
entrants an opt-out into the new
regime. Apparently, this opt-out
will continue to be granted
annually, also in subsequent years.
Under the old regime, actual
taxation on the source State under
the rules of a tax treaty or,
alternatively, no connection of the
income with the Portuguese
territory under the territorial scope
rules of the IRS Code, is required
for the exemption (with
progression) to be applicable. This
last rule exempts pensions which
are not paid by entities with
residence, head office, effective
management or permanent
establishment, to which the
payment relates to, in Portugal.
The third set of rules will be
applicable to active income
deriving from employment,
independent personal services and
also to foreign-sourced income
from intellectual and industrial
property or from the provision of
information relating to experience
gained in the industrial,
commercial or scientific sectors
(know-how), when derived by the
original holder.
Under it, foreign-sourced
employment income will be
exempt from IRS (with
progression, except if it derives
from certain high value added
activities of a scientific, artistic or
technical nature, as defined by
Ministerial Order), provided that it
is taxed in the source State
according to the rules of a tax treaty
entered into by Portugal or, if no
treaty is in place, that it is taxed in
the source State and that it is not
considered to arise from a
Portuguese source under the IRS
Code territoriality rules. Foreign-
sourced income from independent
personal services (i) derived from
high value added activities of a
scientific, artistic or technical
nature, as defined by Ministerial
Order, or (ii) foreign-sourced
income from intellectual and
industrial property or from the
provision of information relating to
experience gained in the industrial,
commercial or scientific sectors
(know-how), when these royalties
were derived by the original holder
will be exempt (without
progression in the first (i) case and
with progression in the second (ii)
one), as long as such income may
be taxed in the source State
according to the rules of a tax treaty
entered into by Portugal or, if no
treaty is in place, that (i) it may be
taxed in the source State according
to the rules of the OECD Model Tax
Convention on Income and on
Capital, as interpreted in the light
of the Portuguese reservations on
its articles and of the observations

5. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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on its commentary; (ii) it is not
considered to arise from a
Portuguese source under the IRS
Code territoriality rules; and (iii)
the source State, region or territory
is not included in the Portuguese
tax havens’ blacklist.
Effective taxation is therefore only
required in regard of employment
income. However, the independent
personal services exemption will
only be applicable to income
derived from certain high value-
added activities of a scientific,
artistic or technical nature, as
defined by Ministerial Order.
High value-added activities’
income deriving from employment
or independent personal services
of a domestic or foreign source
(only if not exempt), are liable to
autonomous taxation at a special
20% flat rate and not to the general
and progressive IRS rates (whose
higher bracket is of 48% for taxable
income above € 75.009 in the tax
year of 2022; moreover, taxpayers
with taxable income above € 80.000
are liable to an additional solidarity
rate of 2,5% on income exceeding
such amount and of 5% on income
exceeding € 250.000 during the tax
year.
NHRs deriving foreign-sourced
income that will be IRS exempt
under both these sets of rules will
be allowed to opt, in its regard, for
the credit method (the standard
method for the elimination of
international double taxation in
Portugal).
Whenever this option is exercised,
the income will be taxed under the
standard IRS regime, being liable
either to progressive rates of up to
48% (plus 2,5% on taxable income
above € 80.000 and 5% on taxable
income above € 250.000 during
2022) or to special lower flat rates,
depending on its nature.
High value-added
activities’ income
deriving from
employment or
independent
personal services of a
domestic or foreign
source (if not
exempt) are liable to
autonomous
taxation at a special
20% flat rate.

6. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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The option for credit must be
exercised on an all-or-nothing
basis, meaning that opting for the
credit method in regard of one
category of income will imply that
the option is extended to all
remaining categories of income
and the exemption method
completely forfeited.
Additionally, NHRs deriving
income taxed at the special 20% flat
rate may also opt for the
progressive IRS rates (of up to 48%,
plus 2,5% on taxable income above
€ 80.000 and 5% on taxable income
above € 250.000, during 2022) in its
regard.
2. The Ministerial Orders
Ministerial Order nr. 12/2010, of
January 7, defined the “high value-
added activities of a scientific,
artistic or technical nature”
qualifying for the regime. The main
feature to be highlighted from this
Order is the fact that
sportspersons’ activities are not
included in its scope, contrarily to
what was initially expected and
thereby departing this regime from
the well-known and so-called
Spanish “Beckham Law”.
An amendment to the list of High
Value-Added Activities, applicable
from January 1, 2020 onwards, was
published on July 23, 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 in
January 1, 2020, and it applies to
individuals registered under the
NHR regime from 2020 onwards.
For NHR registered as such with
effect up to December 31, 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.

7. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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“OLD” LIST (Ministerial Order nr. 12/2010, of January 7)
Portuguese English
1 - Arquitectos, engenheiros e técnicos similares:
101 - Arquitectos;
102 - Engenheiros;
103 - Geólogos.
1 - Architects, engineers and similar technicians:
101 - Architects;
102 - Engineers;
103 - Geologists.
2 - Artistas plásticos, actores e músicos:
201 - Artistas de teatro, bailado, cinema, rádio e
televisão;
202 - Cantores;
203 - Escultores;
204 - Músicos;
205 - Pintores.
2 - Visual artists, actors and musicians:
201 - Theater, ballet, film, radio and television Artists;
202 - Singers;
203 - Sculptors;
204 - Musicians;
205 - Painters.
3 - Auditores:
301 - Auditores;
302 -Consultores fiscais.
3 - Auditors:
301 - Auditors;
302 - Tax Consultants.

8. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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Portuguese English
4 - Médicos e dentistas:
401 - Dentistas;
402 - Médicos analistas;
403 - Médicos cirurgiões;
404 - Médicos de bordo em navios;
405 - Médicos de clínica geral;
406 - Médicos dentistas;
407 - Médicos estomatologistas;
408 - Médicos fisiatras;
409 - Médicos gastroenterologistas;
410 - Médicos oftalmologistas;
411 - Médicos ortopedistas;
412 - Médicos otorrinolaringologistas;
413 - Médicos pediatras;
414 - Médicos radiologistas;
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;
409 - Gastroenterologists;
410 - Ophthalmologists;
411 - Orthopaedists;
412 - Otorhinolaryngologists;
413 - Paediatricians;
414 - Radiologists;

9. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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Portuguese English
415 - Médicos de outras especialidades. 415 - Doctors in other specialties.
5 - Professores:
501 - Professores universitários.
5 - Teachers:
501 - University professors.
6 - Psicólogos:
601 - Psicólogos.
6 - Psychologists:
601 - Psychologists.
7 - Profissões liberais, técnicos e assimilados:
701 - Arqueólogos;
702 - Biólogos e especialistas em ciências da vida;
703 - Programadores informáticos;
704 - Consultoria e programação informática e
actividades relacionadas com as tecnologias da
informação e informática;
705 - Actividades de programação informática;
706 - Actividades de consultoria em informática;
707 - Gestão e exploração de equipamento
informático;
7 - Professional services, technicians and similar:
701 - Archaeologists;
702 - Biologists and experts in life sciences;
703 - Computer Programmers;
704 - Software consultancy and activities related to
information and computer technology;
705 - Computer programming activities;
706 - Computer consultancy activities;
707 - Management and operation of computer
equipment;

10. The Portuguese Non-Habitual
Tax Resident Regime
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Portuguese English
708 - Actividades dos serviços de informação;
709 - Actividades de processamento de dados,
domiciliação de informação e actividades
relacionadas; portais Web;
710 - Actividades de processamento de dados,
domiciliação de informação e actividades
relacionadas;
711 - Outras actividades dos serviços de informação;
712 - Actividades de agências de notícias;
713 - Outras actividades dos serviços de informação;
714 - Actividades de investigação científica e de
desenvolvimento;
715 - Investigação e desenvolvimento das ciências
físicas e naturais;
716 - Investigação e desenvolvimento em
biotecnologia;
717 - Designers.
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 - Investidores, administradores e gestores: 8 - Investors, administrators and managers:

11. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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Portuguese English
801 - Investidores, administradores e gestores de
empresas promotoras de investimento produtivo,
desde que afectos a projectos elegíveis e com contratos
de concessão de benefícios fiscais celebrados ao abrigo
do Código Fiscal do Investimento;
802 - Quadros superiores de empresas.
801 - Investors, administrators and managers of
companies promoting productive investment, if
allocated to eligible projects under tax benefit
contracts awarded under the Tax Code for
Investment;
802 - Senior employees of companies.
“NEW” LIST (Ministerial Order nr. 230/2019, of July 23)
Portuguese English
I - Actividades profissionais (códigos CPP):
112 - Director-geral e gestor executivo, de
empresas
12 - Directores de serviços administrativos e
comerciais
13 - Directores de produção e de serviços
especializados
I - Professional activities (PCP codes):
112 - General manager and executive manager
12 - Manager of administrative and commercial
services (v.g., financial, HR, and strategy)
13 - Production and specialized services’
managers (v.g., farming, livestock, forestry,
fishery, mining industry, transports and others)

12. The Portuguese Non-Habitual
Tax Resident Regime
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Portuguese English
14 - Directores de hotelaria, restauração, comércio
e de outros serviços
21 - Especialistas das ciências físicas,
matemáticas, engenharias e técnicas afins
221 - Médicos
2261 - Médicos dentistas e estomatologistas
231 - Professor dos ensinos universitário e
superior
25 - Especialistas em tecnologias de informação e
comunicação (TIC)
264 - Autores, jornalistas e linguistas
265 - Artistas criativos e das artes do espectáculo
31 - Técnicos e profissões das ciências e
engenharia, de nível intermédio
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 stomatology
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 science and others)

13. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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Portuguese English
35 - Técnicos das tecnologias de informação e
comunicação
61 - Agricultores e trabalhadores qualificados da
agricultura e produção animal, orientados para o
mercado
62 - Trabalhadores qualificados da floresta, pesca
e caça, orientados para o mercado
7 - Trabalhadores qualificados da indústria,
construção e artífices, incluindo nomeadamente
trabalhadores qualificados da metalurgia, da
metalomecânica, da transformação de alimentos,
da madeira, do vestuário, do artesanato, da
impressão, do fabrico de instrumentos de
precisão, joalheiros, artesãos, trabalhadores em
electricidade e em electrónica.
8 - Operadores de instalações e máquinas e
trabalhadores da montagem, nomeadamente
operadores de instalações fixas e máquinas
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

14. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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Portuguese English
Os trabalhadores enquadrados nas actividades
profissionais acima referidas devem ser
possuidores, no mínimo, do nível 4 de
qualificação do Quadro Europeu de Qualificações
ou do nível 35 da Classificação Internacional Tipo
da Educação ou serem detentores de cinco anos
de experiência profissional devidamente
comprovada.
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 - Outras actividades profissionais:
Administradores e gestores de empresas
promotoras de investimento produtivo, desde
que afectos a projectos elegíveis e com contractos
de concessão de benefícios fiscais celebrados ao
abrigo do Código Fiscal do Investimento,
aprovado pelo Decreto-Lei n.º 162/2014, de 31 de
Outubro.
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
October 31, 2014.

15. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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It is important to note that for
individuals that were already
granted the NHR status prior to
2020, both the old and the new
lists of activities may be
considered until the end of the 10-
year period of NHR status.
Similarly, individuals that had a
pending NHR status application
on the January 1, 2020, or that
until March 31, 2020 applied for
such status (with effects to 2019),
shall be eligible to both the old
and new activities’ lists, until the
end of the NHR status’ validity
period of 10 years.
Regarding the activities covered,
since Ministerial Order nr.
230/2019, of July 23, there are new
activities included (managers of
hotel business,
restaurants/catering, trade and
other services, technicians as well
as science and engineering
professions of intermediate level,
farmers, facility and machinery
operators). However, some
previously covered activities are no
longer included (auditors, tax
consultants, archaeologists,
psychologists).
3. The Administrative Rulings
The Portuguese Tax Authority
issued a ruling in May 6, 2010
(Administrative Ruling nr. 2/2010)
dealing with practical aspects of
the regime, namely its application
in 2009 and the requirements to
obtain the NHR status.
Concerning the application of the
regime in 2009, Portuguese Tax
Authority therein assume the
position that the features
depending on the definition of the
qualifying activities (the 20% flat
tax rate for employment and
independent personal services’
income, as well as the exemption
for foreign-sourced independent
personal services’ income) are only
applicable starting from fiscal year
2010.
The remaining features of the
regime (the exemptions for other
types of foreign-sourced income)
were deemed applicable in 2009.
This position raised serious doubts,
as the law sets out that the benefits
of the regime are granted for a ten-
year period. It remains to be seen if
this ten-year period will be taken
into account in different ways,
starting in 2009 for the benefits not
depending on the Ministerial
Order and in 2010 for those which
are.
In regard of the requirements to
obtain the NHR status, the ruling
took the position that for those
becoming Portuguese tax residents
in 2009 the regime would only be

16. The Portuguese Non-Habitual
Tax Resident Regime
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It is sufficient that a
taxpayer states in its
application that he
solemnly declares
that he or she did not
fulfil the conditions
to be considered a
Portuguese tax
resident in the five
preceding tax years.
applied on a case-by-case basis,
and to:
a) taxpayers registering as tax
residents “under the
assumption that they would
be covered by the regime”;
and
b) doing so after September 23,
2009, the publication date of
the Decree-Law approving
the regime.
Both requirements may be
viewed as illegal, as the Decree-
Law clearly establishes that it is
applicable starting from January
1, 2009.
A second ruling has been issued
in August 3, 2012 (Administrative
Ruling nr. 9/2012).
Among other minor features (all
already clearly established by
law), this ruling has changed the
Tax Authority’ position
concerning the requirements to
obtain the NHR status. Under the
new ruling, it is sufficient that a
taxpayer adds to its application to
the regime a statement under
which he solemnly declares that
he or she did not fulfil the
conditions to be considered a
Portuguese tax resident in the five
preceding tax years, either under
our domestic law or by effect of a
tax treaty entered into by
Portugal.
This ruling partially revokes
ruling nr. 2/2010, which (illegally)
required taxpayers to present
upon application foreign
certificates of residence and
certificates establishing that they
had suffered an effective tax
burden abroad in the five tax
years preceding their
redomiciliation into Portugal.

17. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
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This change renders new
applications to the regime
significantly less burdensome
and will also unblock previously
submitted applications whose
decision was being delayed by
the lack of any of the mentioned
documents, as ruling nr. 9/2012
expressly states that it is
applicable to pending
applications.
Finally, it must be noted that, vis-à-
vis activity code 802 - senior
employees of companies, ruling nr.
2/2010 has adopted a very
restrictive view, which has
remained unchanged by ruling nr.
9/2012. According to this view,
only persons with management
roles and powers to bind
companies may fit into this
category, which is an
incomprehensible position, as
usually only members of corporate
bodies (maxime, members of the
board) have such powers and the
concept of “senior employees of
companies” must naturally differ
from that of “investors, directors
and managers”. Despite this
position, it should be said that, in
practice, this activity code has been
recognised by the Tax authority on
requests by taxpayers with more
leeway than one might anticipate
given the rulings’ position.
Ruling nr. 2/2010 has also clarified
that those employed in companies
fully or partially owned by the
Portuguese State, Autonomous
Regions and Municipalities and
those in charge of a Portuguese
permanent establishment of a non-
resident company also qualify for
activity code 801 - investors,
administrators and managers of
companies promoting productive
investment, provided of course
that such companies and
permanent establishments have
entered into tax benefit contracts
under the Tax Code for Investment
and that the activity of such
persons is allocated to the specific
projects giving rise to the tax
benefit contracts.
4. State Budget Law for 2012
Law nr. 64-B/2011, of December 30,
which approved the State Budget
Law for 2012, has introduced a new
20% withholding tax rate for
domestic source employment or
independent personal services
income deriving from high value-
added activities of a scientific,
artistic or technical nature.
This rate, applicable from January
1, 2012 onwards, means that NHRs
with domestic source income of
these categories are, from that date
on, no longer liable to the standard

18. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
18
withholding tax rates of up to
43,8% (in 2022) for employment
income (depending on the amount
of the income and on their personal
and family circumstances) and of
25% for independent personal
services income.
This solved the previous problem
of the tax paid in advance during
the year being higher than the final
tax due, as such income is liable to
a special 20% flat tax rate and not
to the general and progressive rates
of up to 48% (plus 2,5% on taxable
income above € 80.000 and 5% on
taxable income above € 250.000
during 2022), as mentioned in
point 1. above.
5. Amended State Budget Law for
2012
Law nr. 20/2012, of May 14 - the
Amended State Budget Law for
2012 -, introduced a term for the
submission of applications to the
NHR regime.
Under the changes introduced to
the IRS Code, applications must
now be submitted until March 31 of
the tax year following that in which
Portuguese tax residence is
acquired.
It has been expressly established in
the Amended State Budget Law for
2012 that such deadline was
previously non-existent, which
means that applications previously
denied on the grounds of being
extemporaneous and still pending
appreciation, namely due to the
submission of administrative
appeals, will now be decided
favourably. It is also possible that
cases of applications previously
denied on the grounds of being
The State Budget
Law for 2012
introduced a 20%
withholding tax rate
for domestic source
employment or
independent personal
services income
deriving from high
value-added
activities of a
scientific, artistic or
technical nature.

19. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
19
The State Budget
Law for 2013
introduced an
extraordinary surtax
of 3,5%.
extemporaneous and already fully
decided (i.e., where no appeals are
pending) might again be submitted
to the Portuguese Tax authority,
although this should be
approached with care.
6. State Budget Law for 2013
The State Budget Law for 2013
(Law nr. 66-B/2013, of December
31) introduced two changes to the
regime.
One of them was that taxable
income of individuals became
subject to an extraordinary surtax
of 3,5% in 2013, applicable to the
employment or independent
personal services income deriving
from high value-added activities of
a scientific, artistic or technical
nature obtained by NHRs liable to
autonomous taxation at a special
20% flat rate, as well as to any non-
exempt income liable to the general
and progressive IRS rates.
In the case of employment income
deriving from high value-added
activities of a scientific, artistic or
technical nature, the 3,5%
surcharge was added to the 20%
withholding tax rate introduced by
the State Budget Law for 2012. In
the case of independent personal
services income of the same nature
the surcharge was only levied
upon the submission of the yearly
tax return.
The second aspect of State Budget
Law for 2013 was a change to the
wording of paragraphs (3), (4) and
(5) of article 81 of the IRS Code,
which establish the conditions for
the exemption of (i) employment
income; (ii) independent
professional services income
obtained through high value-
added activities, royalties, capital

20. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
20
income, rental income and capital
gains; and (iii) pension income,
respectively.
This change is, in our opinion,
irrelevant, in all cases, as it does not
amend the already previously tax-
exempt status of such items of
income.
However, as far as pension income
is concerned, it had the intention to
put an end to an abusive
interpretation by the Tax authority
of the second condition of
paragraph (5) of article 81 of the
IRS Code, according to which the
non-taxation of non-Portuguese
sourced pensions applies only in
cases where no tax treaty exists.
This interpretation had no
sustenance, as the tax exemption
for foreign sourced pensions was
clearly applicable to pensions
sourced in States with which
Portugal both had and had not
entered into a tax treaty. Moreover,
it made no sense to sustain this
position, as it would imply that
foreign pensions earned by NHRs
which had not been taxed at source
would be exempt if they originated
from tax havens (with no tax treaty
with Portugal) but would be
taxable if they originated from
States with a tax treaty entered into
with Portugal.
Other additional problems have
also arisen in the application of the
regime, especially deriving from
the poor adaptation of the IRS
return form to some of the regime’s
features. Namely, the tax return
form seemed to require that
pensions were taxed abroad for
them to be IRS exempt under the
regime (which, we stress again, is
not legally required) and the
electronic filing system seemed to
have been configured in a way that
raised difficulties in the application
of the regime to passive income,
such as capital income, rental
income, royalties and capital gains
on real estate.
The Tax authority’s interpretation,
together with the poor drafting of
the IRS return form, raised
practical and important doubts on
the application of the regime
concerning pensions which were
not fully clarified with the very
subtle change deriving from the
State Budget Law for 2013.
The effects of that change have
been debated. As the new wording
was enacted without retroactive or
interpretative effect, it remained
doubtful whether the Tax
Authority would accept to apply
the exemption for pension income
to pensions received until
December 31, 2012, and sourced in

21. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
21
States with which Portugal has
entered into a tax treaty.
7. Other developments in 2013
It was expected that an
administrative ruling would be
issued by the Secretary of State of
Tax Affairs or the Director-General
of Taxes in the aftermath of the said
legislative change, to fully
eradicate the existing doubts.
However, the expected
clarifications emerged more
prosaically, with the issuing in
December 2012 of tax assessments
for taxpayers under the regime and
with no foreign sourced pension
income, and with the issuing in the
end of March 2013 of tax
assessments for taxpayers with
foreign sourced pension income.
Tax assessments for taxpayers
under the regime were pending
issuance since its inception, which
was previously a source of major
concern regarding its practical
application. The regime clearly
then became fully applied by the
Portuguese Tax authority.
The said assessments were,
however, incorrectly issued as
regards foreign sourced capital
income, rental income, royalties
and capital gains on real estate, as
these were deemed taxable even
when the requirements for their
exemption – (a) possibility of
taxation at source according to the
rules of a tax treaty entered into by
Portugal or, if no treaty is in place,
(b) that (i) it may be taxed in the
source State according to the rules
of the OECD Model Tax
Convention on Income and on
Capital, as interpreted in the light
of the Portuguese reservations on
its articles and of the observations
The Tax authority’s
interpretation and the
poor drafting of the
IRS return form have
raised practical and
important doubts in
the past on the
application of the
regime concerning
pensions. However,
the regime is now
fully applied by
Portuguese Tax
Authority.

22. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
22
Registering as a tax
resident in Portugal
is a requirement to
be granted the NHR
status.
on its commentary; (ii) it is not
considered to arise from a
Portuguese source under the IRS
Code territoriality rules; and (iii)
the source State, region or territory
is not included in the Portuguese
tax havens’ blacklist - were
verified.
In certain cases, taxpayers were
forced to submit administrative
appeals against assessments
bearing such a mistake, to be fully
protected.
This problem was also solved at the
end of 2013. Pending appeals were
decided in favour of taxpayers and
Portuguese Tax Authority have
issued corrective tax assessments
replacing all assessments suffering
from this mistake, even those not
under appeal.
8. Changes to the procedure to
register as tax resident in
Portugal
Decree-Law nr. 14/2013, of January
18, changed the rules applicable to
the registration of taxpayers. Non-
Portuguese nationals are now
required to obtain a valid residence
permit or a long-term residence
certificate to register as tax
residents in Portugal, something
which was previously not
required, at least in theory.
Registering as a tax resident in
Portugal is a requirement to be
granted the NHR status, which
means that those wishing to apply
for the regime must now: (i)
register as non-resident taxpayers;
(ii) obtain residence permits (for
non-EU nationals) or long-term
residence certificates (for EU
nationals); (iii) register as tax
residents; (iv) request the password

23. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
23
to access the Tax Authority’s
website; and (v) only then apply for
the NHR status. Decree-Law nr.
41/2016, of August 1, also changed
the means of application to the
NHR status, which is now
submitted via the Tax Authority’s
website.
9. State Budget Law for 2014 and
subsequent developments
The State Budget Law for 2014
(Law nr. 83-C/2013, of December
31) once again approved a 3,5%
extraordinary surtax, applicable in
the exact same terms as the one in
force during 2013.
Moreover, Ministerial Order nr.
365/2013, of December 23,
approved a new IRS return form,
applicable to returns submitted as
from January 1, 2014, concerning
income obtained in preceding tax
years.
Following the clarifications of 2013
in regard of pensions and passive
income, the changes introduced to
the form clarified that only foreign-
sourced employment income must
be effectively taxed by the State of
source to qualify for the NHR
exemptions.
In fact, the form now expressly
states that (i) all foreign sourced
pensions and (ii) foreign sourced
passive income that is liable to tax
at the State of source is tax exempt
in Portugal, regardless of effective
taxation abroad.
10. Expected changes for 2015 - the
IRS Code Reform
The Commission charged with the
2014 IRS reform, which entered
into force on January 1, 2015, had
proposed to the Government the
enactment of significant changes to
The changes
introduced to the
form clarify that
only foreign-sourced
employment income
must be effectively
taxed by the State of
source to qualify for
the NHR
exemptions.

24. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
24
the NHR regime, directed at
increasing its attractiveness.
The most relevant proposed
change was a widening of the
exemptions for foreign-sourced
income to encompass: (i) all
passive income (interest,
dividends, royalties, other income
from capital, capital gains on any
foreign asset, including shares, and
income from immovable property),
regardless of the liability to
potential taxation at source under
an existing tax treaty or the OECD
Model Tax Convention; and (ii)
independent personal services
income of any kind, provided that
it is potentially liable to taxation in
the source State under the rules of
a tax treaty or of the OECD Model
Tax Convention.
Moreover, the Commission also
proposed the inclusion of
actuaries, airline pilots and
directors and managers of all
companies, regardless of their
activity sector and of the existence
of a tax benefit contract with the
Portuguese State, in the list of high
value-added activities of a
scientific, artistic or technical
nature which qualify non-exempt
employment and independent
personal services income for the
special 20% flat rate.
This inclusion would operate
through an amendment to the first
Ministerial Order mentioned above
in point 2.
Finally, the Commission also
proposed the abolishing of an
existing withholding tax,
applicable to cases where exempt
foreign-sourced income derived by
NHRs from securities is paid
through Portuguese entities, as in
practice the withholding was
rendering the exemption
ineffective in such cases.
11. Effective changes for 2015
Despite high expectations, only the
last of the mentioned changes
proposed by the Commission
charged with the 2014 IRS Reform
was approved.
However, additions to the list of
high value-added activities of a
scientific, artistic or technical nature
– which qualify non-exempt
employment and independent
personal services income for the
special 20% flat rate – do not require
legislative action, but only a change
in the Ministerial Order approving
the list, and therefore may simply
be approved by the Minister of
Finance.
Additionally, there have been
changes to more general aspects of
the IRS Code which may impact the

25. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
25
NHR regime. The most relevant is
the option granted to NHRs
deriving foreign-sourced income
that will be IRS exempt to opt for
progressive rates (of up to 48%, plus
2,5% on taxable income above €
80.000 and 5% on taxable income
above € 250.000, during 2022) in its
regard.
In fact, whereas in the past this
option had to be exercised on an all-
or-nothing basis, meaning that if
exercised in regard of one category
of income all remaining categories
would be subject to the said
progressive rates, with the credit
method being applied and the
exemption method forfeited in
regard of all of them, it is now
possible to opt for the progressive
IRS rates on a per-income category
basis.
This means that it is now possible to
have income from one category
taxed under the IRS progressive
rates, with the credit method being
applicable, and the remaining ones
still benefiting from the applicable
exemptions or special rates.
The main advantage of this option
is that the application of the
progressive rates enables the carry-
forward of losses (between 5 and 12
years) in the categories of income
where it is applicable. As the
application of the progressive IRS
rates to a category of income in
which losses are registered in a
given year and in regard of which
the carry forward of losses is
available in general terms no longer
implies the forfeiting of the
exemption method in regard of the
remaining categories of income, this
option, together with an also new
possibility to carry forward existing
excess foreign tax credit (during 5
years), may prove beneficial with
regard to income not encompassed
by the NHR exemptions.
Additionally, this option, in our
opinion and according to the tax
assessments that we have seen by
the Portuguese Tax Authority, does
not imply the forfeiting of the
exemption granted by the NHR
regime on passive income, i.e. the
exemption remains applicable.
However, the respective income
will be taken into consideration to
determine the progressive tax rates
applicable to non-exempt income.
The option for the credit method
regarding exempt income remains
available, but it is still applicable on
an all-or-nothing basis, meaning
that, when exercised in regard of
one category of income, income of
all categories will be taxed under
the standard IRS regime, being
liable either to progressive rates of
up to 48% (plus 2,5% on taxable

26. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
26
income above € 80.000 and 5% on
taxable income above € 250.000,
during 2022) or to special lower flat
rates, depending on its nature. This
option also implies that the credit
method will be applied to income of
all categories and the exemption
method completely forfeited.
The consequences of the options for
the IRS progressive rates and for the
credit method may be summarized
as follows:
Option for the
IRS
progressive
rates
Per-category
basis.
Credit method
applicable to the
income
effectively
taxed.
Exemption
retained, but
with
progression, on
exempt income
subject to
progressive tax
rates due to an
option of the
taxpayer.
Exemption and
special rates
retained on
remaining
categories.
Option for the
credit method
All-or-nothing
basis.
Exemption lost
on all categories
of income.
Special rates
retained on
remaining
categories,
whenever
applicable.
Finally, the State Budget Law for
2015 (Law nr. 82-B/2014, of
December 31) has once again
approved a 3,5% extraordinary
surtax, applicable in the exact same
terms as the one in force during 2013
and 2014.
12. Other tax features and
planning opportunities
Law nr. 15/2010, of June 26, has
abolished a long-standing IRS
exclusion for capital gains on shares
held for more than 12 months.
This has relevant consequences for
the NHR regime, as its tax
exemption for capital gains had been
built with that exclusion in mind and
in such a way that it is only
applicable if the income may be
taxed in the source State under the
rules of a tax treaty entered into by
Portugal (or, if no treaty exists,
according to the rules of the OECD
Model Tax Convention on Income
and on Capital, as interpreted in
light of the Portuguese reservations

27. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
27
Most capital gains
(maxime on foreign
shareholdings and
other securities)
remain taxable in
Portugal.
on its articles and of the observations
on its commentary).
This implies that most capital gains
(maxime on foreign shareholdings
and other securities) will remain
taxable in Portugal as both most of
the Portuguese tax treaties and the
OECD Model Tax Convention
establish in this case that the
residence state has exclusive
competence to tax.
Additionally, several other attractive
features remain for the Portuguese
taxation of individuals.
Firstly, several capital gains are
excluded from IRS taxation, such as
those on:
a) shares and quotas, acquired
before January 1, 1989;
b) real estate, except land for
construction, owned before
January 1, 1989;
c) PIT capital gains on the sale of a
taxpayer's personal and
permanent residence are not
taxable, insofar as the sale
proceeds are reinvested in
another personal residence in
the Portuguese, European
Union or European Economic
Area territory (in the latter case
if there is an instrument
providing for exchange of
information between the Tax
Authorities of both States in
terms similar to the ones in force
within the European Union).
Alternatively, those sale
proceeds may be reinvested in
contributions to the public
capitalization regime or in a life
insurance contract or open
pension fund that generates
periodic payments, insofar as
the taxpayer or the spouse or
civil partner is at least 65 years
of age or retired. It is also

28. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
28
necessary that the investments
aim exclusively to provide the
acquirer or his spouse or civil
partner with a regular periodic
provision for a period of 10
years or more, with a maximum
annual amount equal to 7.5% of
the amount invested.
Contributions made by the
employer to pension funds and life
and health insurance schemes are
not regarded as employment
income provided that certain
conditions are met.
Finally, since January 1, 2004, close
family (spouses, children,
grandchildren, parents and
grandparents) is exempt from
Stamp Tax on gifts and
inheritances. Other situations
involving the gratuitous disposal
of Portuguese assets are taxed
through a 10% (or 10,8% when a
gift of Portuguese real estate is
concerned) Stamp Tax.
However, the disposal of foreign
assets, even towards Portuguese
residents (such as the disposal of (i)
shares in companies whose head-
office, effective management or
permanent establishment is not in
Portuguese territory, and of (ii)
credit rights or rights with an
economic content over individuals
or companies, with residence,
head-office, effective management
or a permanent establishment
outside of Portugal), is not liable to
this type of taxation.
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,

29. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
29
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 programs of 2019
and 2022 and the Socialist
Government programs for the
2019-2023 and 2022-2026
legislatures have no mention
whatsoever to changes in
inheritance taxation. Nevertheless,
developments on this issue should
be monitored.
B. Endnotes on the status of the
regime and on its predictable
developments
1. Extraordinary surtax
The State Budget Law for 2017
(Law nr. 42/2016, of December 28)
once again maintained an
extraordinary surtax, applicable to
employment or independent
personal services income, deriving
from high value-added activities of
a scientific, artistic or technical
nature, obtained by NHRs liable to
autonomous taxation at a special
20% flat rate, as well as to any non-
exempt income liable to the general
and progressive IRS rates.
However, such surtax became
progressive, being that the higher
bracket – for income above € 80.640
– was taxed via a 3,21% rate.
The extraordinary surtax was
finally revoked by the end of 2017.
2. Tax treaties
A renegotiation of tax treaties in
force between Portugal and other
States was recently an issue with
two Nordic countries, and was
driven by the double non-taxation
of private pensions allowed by the
combination of the old NHR
pension regime with tax treaties
following the OECD Model Tax
Convention. The two countries
were Sweden and Finland. In the
case of Finland, the tax treaty was
unilaterally terminated with effects
as from January 1, 2019, although
its Government requested an
amendment to the private pension
article of the tax treaty that was
accepted by the Portuguese
Government. Sweden also
expressed the desire to revise the
same provision in its tax treaty
with Portugal and negotiations
resulted in a Protocol to the tax
treaty, signed in May 2019. This
Protocol foresaw that Sweden, as
the source State of private
pensions, had the right to impose

30. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
30
tax on them, under certain
circumstances (Sweden’s existing
tax treaty with Portugal already
allowed Swedish taxation on
disbursements made under the
Swedish Social Security legislation
and paid to Portuguese tax
residents). However, and due to
the delay of the Portuguese
Government in complying with the
required procedures to enable the
ratification of the Protocol, Sweden
decided to step back and
unilaterality terminate the tax
treaty, with effects as from 1
January 2022, being that the
Protocol never entered into force.
For NHR receiving pension income
from Sweden, this termination
means that any tax levied in
Sweden will be credited against the
Portuguese tax due on the
pensions, if any (in particular
against the 10% flat tax for foreign
pensions applicable entrants in the
regime after 1 April 2020). As
Sweden is not a blacklisted
jurisdiction the NHR taxation in
Portugal of dividend and interest
income sourced in Sweden should
not be adversely: the exemption
method will apply to the income
streams that may be taxed in
Sweden, as the source State,
according to the rules of the OECD
Model Tax Convention on Income
and on Capital, as interpreted in
the light of the Portuguese
reservations on its articles and of
the observations on its
commentary. Currently no other
State has publicly signalled a will
to revise its tax treaty with Portugal
due to this topic.
3. High value-added activities
The previous Government had
already indicated the intention of
revising the list of high value-
added activities of a scientific,
artistic or technical nature – which
qualify non-exempt employment
and independent personal services
income for the special 20% flat rate.
As already mentioned in A.2. above,
an amendment to the list of high
value-added activities was
published by Ministerial Order no.
230/2019, of July 23.
Also in 2019 the Portuguese Tax
Authority decided to change the
way they control these activities. The
changes were communicated in
General Ruling 4/2019, of October 8.
Until then, an administrative
procedure involving a prior
recognition - that in principle took
place simultaneously with the
request for registration as an NHR –
was in place. This procedure,
however, was very lengthy and did
not rule out a subsequent control,
after the tax return delivery, with
respect to the compliance with the

31. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
31
underlying requirements. From
October 8, 2019, onwards, any NHR
who wishes to benefit from the tax
regime applicable to the high value-
added activities needs only to refer
the respective activity code in the
duly filled in annual tax return,
without any need to obtain a prior
recognition for it. This new
procedure shall not prevent the
Portuguese Tax Authority from
subsequently requiring the NHR to
prove that he or she exercises the
activity in question. It allows the
worker to submit proof, namely an
employment or supply of services
contract, a registration in a
Professional Association, a
document proving that he or she has
a specific administrative position, a
tax and social security declaration
attesting the beginning of the
activity - in the case of self-employed
workers, or other official documents
that serve as evidence of the invoked
activity.
The tax regime for NHRs seems to be
effective in the attraction to Portugal
of high net worth individuals,
increasing demand in the domestic
market, and fostering increased
fiscal revenue, namely in regard of
real estate and consumption taxes,
from individuals that otherwise
might not be taxpayers in Portugal.
It also incentivises the return of
highly qualified Portuguese
nationals domiciled abroad.
The Government that ruled until
October 30, 2015, had announced the
intention to implement a specific
program to boost the attractiveness
of Portugal as a destination for
northern European retirees - the
retirement in the Sun (“Reforma ao
Sol”) Program.
The NHR regime
seems to be effective
in the attraction to
Portugal of high net
worth individuals.

32. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
32
This Program never came to light,
possibly because the NHR - which,
as from January 1, 2014, may be fully
and unrestrictedly enjoyed by those
wishing to move to Portugal - has
proved sufficient in this regard.
***
Proper legal advice is
recommended before any decision
is taken to become a Portuguese tax
resident, and more so if one wants
to profit from the NHR status.
RPBA has an in-depth knowledge
and expertise on this regime.
Visit our microsite to know more
about the NHR regime.
To obtain our professional fees or
to book a consultation please
e-mail us at:
communication@rpba.pt
Ricardo da Palma Borges
Carlos Alcântara Neves
Alexandra Esteves Lopes
António Freitas Vilar
Carolina Silva Esteves
Inês Falcão Fernandes
(formerly, also Pedro Ribeiro de
Sousa)

33. The Portuguese Non-Habitual
Tax Resident Regime
Julho 2014
33
Disclaimer:
■ In the preparation of this
Information Note, 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
October 13, 2022.
■ This Information Note 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 Information
Note should be used as a research
tool only, and not in lieu of
individual professional study with
respect to client legal matters.
■ RICARDO da PALMA BORGES
& ASSOCIADOS, SOCIEDADE DE
ADVOGADOS, S.P., R.L. is the
copyright owner of this
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