The Non-Habitual Resident (NHR) tax regime in Portugal was repealed as of January 1, 2024, and replaced by the Tax Incentive for Scientific Research and Innovation.
The Portuguese Tax and Customs Authority (Autoridade Tributária e Aduaneira - AT) issued rules that define who may still benefit from the transitional NHR regime and how to apply.
Transitional regime and application requirements
Despite the revocation, the NHR scheme continues to apply to persons who were already registered as NHRs on January 1, 2024. These individuals keep all benefits until the end of their original 10-year period.
Core Eligibility Conditions
To request NHR status, the applicant must be 18 or older and meet both conditions:
- Tax Residency: The person must be considered a tax resident in Portuguese territory
- Prior Non-Residency: The person must not have been considered resident in Portuguese territory in any of the five years prior to the year for which the NHR registration is required
The 2024 Registration Exception
A special transitional rule allows citizens who became tax resident in Portugal by December 31, 2024, to submit their application for NHR registration with effect from 2024.
In addition to meeting the core requirements, these applicants must declare they fulfil the established conditions and must have supporting evidence that demonstrates a prior link to Portugal. These documents include:
- A promise or contract of employment, or posting agreement, concluded by December 31, 2023
- A lease agreement or similar agreement granting the use or possession of real estate in Portugal concluded until October 10, 2023
- A valid residence visa or permit (or proof that the application process began) by December 31, 2023
These documents may be audited later by AT.
Deadlines and effects of late application
The deadline for submitting the NHR registration application with effect from 2024 was March 31, 2025.
If submitted after March 31, 2025, and is granted:
- The NHR regime only takes effect from the year in which the application is formally made (e.g., 2025 or later)
- The benefit period will only be granted for the remaining years until the end of the 10th consecutive year, counted from 2024 (the year the taxpayer became resident).
Example: A person who became resident in 2024 but applies on April 1, 2025, will start the NHR benefit in 2025 but the benefit will still end in 2033, effectively losing one year of the tax regime.
The registration process
The entire NHR registration process is completed and monitored through the
Portal das Finanças and requires these steps:
- Obtain Login Credentials: Request an access password on the Portal using the Registar-se option.
- Update tax residency status: NHR applications can only be submitted by taxpayers registered as residents. If the NIF is still registered as non-resident, the change must be requested:
- Online, via the e-balcão service, or
- In person: at a local Tax Office (Serviço de Finanças) or Citizen's Shop (Loja do Cidadão). You must schedule an appointment in advance.
- Submit NHR Request: Go to: Dados Cadastrais > Residente não Habitual > Entregar Pedido:
- Fill the form with:
- The start year
- The country of previous residence
- A declaration confirming compliance with the 5-year non-residency requirement
- Check application status: You can track the request and download the official proof (PDF) via Dados Cadastrais > Residente não Habitual > Consultar Pedido
Notifications and Prior Hearing
All notifications related to the NHR request are sent to the taxpayer’s tax address.
If AT issues a preliminary rejection, the taxpayer has the right to a Prior Hearing.
During this stage, additional statements or documents (PDF, max 5 MB each) may be submitted online through Dados Cadastrais > Residente não Habitual > Gerir Pedido.
This is the key moment to present any clarification or supporting evidence.
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