NHR 2.0 vs old NHR: What changed and who qualifies (2026)

The original NHR regime closed to new entrants on 31 December 2023, while existing holders continue their individual ten-year periods under the applicable rules.

What is NHR 2.0 in Portugal?

NHR 2.0 in Portugal is the common name for IFICI, or Incentivo Fiscal à Investigação Científica e Inovação, an income tax incentive created under article 58.º-A of the Estatuto dos Benefícios Fiscais (EBF). IFICI is a tax regime, not a visa, and the Autoridade Tributária states that its purpose is to attract talent and encourage scientific research and innovation.

IFICI is narrower than the original NHR tax regime. The IFICI solution page explains the current regime, but eligibility depends on a person's activity, income, entity and tax-residency history. Legislation and administrative requirements may change.

NHR 2.0 at a glance:

• Legal name: Incentivo Fiscal à Investigação Científica e Inovação, commonly abbreviated as IFICI.
• Legal basis: Article 58.º-A of Portugal's Estatuto dos Benefícios Fiscais.
• Who may qualify: New Portuguese tax residents who carry out a defined qualifying activity and meet the regime's other conditions.
• Tax residency: Portuguese tax residency is separate from immigration residency. A Portuguese residence permit or Golden Visa does not, by itself, make a person Portuguese tax resident.
• Duration: IFICI may apply for 10 consecutive years, subject to continued eligibility, and may resume after an interruption for the remaining years when the conditions are met.

What was the original NHR tax regime?

The original NHR regime was Portugal's former Non-Habitual Resident tax regime for eligible individuals who entered it before the regime closed to new applicants. Each holder continues under an individual ten-year period, which cannot be renewed or extended. The closure therefore did not set one end date for everyone.

The original NHR regime closed to new entrants on 31 December 2023. A holder therefore needs to distinguish continuation of the current period from consideration of a separate IFICI application. The guide on the end-of-NHR status frames the end of an individual NHR period as a long-term planning milestone, not a tax emergency.

Income treatment under the original NHR regime varied by income category, so a rate-by-rate comparison depends on the current official table for each category.

IFICI vs old NHR: What changed?

The main change from NHR to IFICI is a move from the original regime to a narrower, activity-based incentive with defined entry conditions. IFICI requires a qualifying activity and does not automatically continue or transfer benefits for people who previously benefited from NHR. The comparison below separates verified structural differences from unsupported historical rate claims.

Availability and entry rules

The original NHR regime is not available to new applicants. IFICI is available only under its own conditions, so the end of NHR does not mean that every new Portuguese tax resident can enter NHR 2.0. The Autoridade Tributária's IFICI FAQ sets out the current registration route and eligibility conditions.

IFICI registration must be submitted through the Portal das Finanças by 15 January of the year after the person becomes a Portuguese tax resident. The Autoridade Tributária states that late registration takes effect from the year it is made and runs for the remaining legal period.

Who can qualify

IFICI eligibility depends on three baseline conditions. The person must not have been a Portuguese tax resident in the previous five years, must become a Portuguese tax resident and must carry out a qualifying activity with income within article 58.º-A of the EBF. A person must also not benefit or have benefited from NHR, must not have opted for article 12.º-A taxation and must not have previously benefited from IFICI.

Qualifying activity categories include scientific research, higher-education teaching, highly qualified professions, qualifying positions in recognised economic activities, research and development, certified start-ups, and other statutory routes. The assessing body varies by activity and may include FCT, AICEP, the Autoridade Tributária, IAPMEI, ANI or Startup Portugal.

Duration and continuity

NHR and IFICI have different duration rules, but neither creates an automatic new entitlement. An NHR holder keeps an individual ten-year period without renewal or extension. IFICI lasts for 10 consecutive years and may resume after an interruption for the remaining years if the person again meets the conditions.

A change of employer or activity does not restart the IFICI period. According to the Autoridade Tributária's IFICI FAQ, the change must be reported through the Portal das Finanças by 15 January of the following year, and a new registration must be filed. The original ten-year period continues for the remaining years.

How Is IFICI different for income and tax treatment?

IFICI and NHR differ in income treatment, but a reliable comparison needs current official rates for both regimes. According to the Autoridade Tributária, IFICI may apply a special 20% rate to qualifying Portuguese-source category A and B income and may exempt certain foreign-source income, subject to conditions.

Portuguese-source qualifying income

IFICI may apply a special 20% rate to Portuguese-source employment income in category A and self-employment income in category B from the qualifying activity, provided the regime's requirements are met. Other Portuguese-source income follows the general IRS regime according to the Autoridade Tributária's IFICI FAQ.

The 20% treatment is not a universal rate for every person or every income source. A qualifying activity, the applicable entity conditions and continued eligibility all matter, and Portuguese tax legislation may change.

Foreign-source income and pensions

IFICI may exempt foreign-source income from IRS as a general rule, except for category H income, depending on the income type, source, and double-tax-treaty position. The Autoridade Tributária also states that income paid by non-resident entities in a jurisdiction on the Ministry of Finance's more-favourable-regime list is taxed at 35% under the stated withholding or autonomous-treatment rules.

Category H income means pension income under the Código do IRS, and foreign pension income does not receive preferential treatment under IFICI. Pensions and other non-qualifying income may be taxed under standard progressive rates. Pension treatment under the original NHR regime depended on when the holder registered, so a pension comparison needs the holder's own registration details.

IFICI foreign-income treatment is conditional and is not a general exemption. The relevant income type, source-country rules, the double tax treaty, and whether the income is treated as Portuguese-source can affect the result. Exempt income may still affect the rate applied to other income.

Can existing NHR holders move to IFICI?

An NHR holder cannot automatically move into IFICI. The Autoridade Tributária's IFICI FAQ states that people who have benefited from NHR are excluded under one of the listed conditions. The holder may continue the individual ten-year period, but continuing NHR and applying for a new IFICI are separate questions.

Three questions stay separate: whether the current NHR period continues, whether the income and activity fit another current regime and which points need an appropriately qualified tax professional. Portugal Pathways provides information and introductions, not regulated tax advice.

What should existing NHR holders review?

Existing NHR holders should record the end year of their individual ten-year period and keep NHR continuation separate from IFICI eligibility. Post-NHR considerations vary by income sources, asset structure, nationality, tax-residency status, family circumstances and existing arrangements, so an appropriately qualified tax adviser should review the position.

Existing NHR holders can work through the review in this order:

1. Confirm whether the person is an existing NHR holder and record the end year of that individual ten-year period.
2. Separate continuation of the current NHR period from IFICI eligibility. Previous NHR eligibility does not transfer automatically to IFICI.
3. Review income sources, asset structure, nationality, tax-residency status, family circumstances and existing arrangements, because post-NHR considerations vary.
4. If IFICI is being considered, check the qualifying activity, entity, prior five-year tax-residency history and any NHR history with a regulated professional.
5. Note the 15 January IFICI registration deadline if the person becomes Portuguese tax resident.
6. Begin a long-term review early without framing the end of NHR as a tax emergency or implying a particular result.

Early review may provide more time to understand future planning considerations and available options.

Frequently asked questions about NHR 2.0 and IFICI

Does NHR 2.0 apply to retirees and pension income?

No, NHR 2.0 does not generally provide preferential treatment for retirees or pension income. IFICI targets active, highly qualified professionals in specified fields, and foreign pension income does not receive preferential treatment. Eligibility still depends on the specific activity, income and tax-residency conditions.

Can someone who previously used NHR apply for IFICI?

No, a person who previously benefited from NHR does not meet the relevant IFICI condition in the Autoridade Tributária's FAQ. A holder may continue the individual ten-year period under the original rules, but that continuation is separate from applying for IFICI and creates no automatic transfer.

Does IFICI restart the ten-year period after a change of activity?

No, IFICI does not restart the ten-year period after a change of activity. The Autoridade Tributária states that a beneficiary must report the change by 15 January of the following year and submit a new registration. The ten-year benefit continues for the remaining years if the requirements remain satisfied.

Is NHR 2.0 available to every new Portuguese tax resident?

No, NHR 2.0 is not available to every new Portuguese tax resident. IFICI requires the person to meet the five-year prior-residence condition, carry out a defined qualifying activity and satisfy the regime's other requirements. A person must also not have benefited from NHR or previously benefited from IFICI.

Reviewing NHR or IFICI status with qualified professionals

The comparison between NHR and IFICI depends on the status of any existing NHR period, the activity and income involved, the person's tax-residency history, and current legislation. Portugal Pathways is an integrated information, introductions and advisory platform that provides information and introductions to appropriately qualified professionals rather than regulated tax advice. The IFICI tax regime page provides further information.

Existing NHR holders and people considering IFICI can contact Portugal Pathways to discuss their circumstances and be introduced to appropriately qualified professionals.

Portugal Pathways provides general information and introductions and does not offer regulated investment, tax, legal or immigration advice. Residency approval is discretionary and subject to AIMA review and applicable Portuguese law. Tax residency is determined separately from immigration residency according to Portuguese tax law and individual circumstances. The value of luxury new homes and qualifying investments may rise or fall; past performance is not a reliable indicator of future results. Where investment routes for the Golden Visa are referenced, investments are offered by independent, regulated fund managers; capital is at risk. Qualifying routes, investment thresholds and physical presence requirements are subject to Portuguese legislation and may change. Readers should obtain independent professional advice before making decisions about investment, residency, citizenship, tax residency, luxury new home acquisitions, or estate or succession planning.

Last reviewed: 29 September 2026

Sources:

• Autoridade Tributária e Aduaneira, IRS > Incentivo Fiscal - IFICI, perguntas frequentes, accessed 29 September 2026 (questions 5494, 5495, 5496, 5498, 5513, 5516, 5517 and 5857).
• Autoridade Tributária e Aduaneira, Código do IRS, articles 1.º and 11.º, accessed 29 September 2026.