Portugal's NHR is closed — and its replacement, IFICI, won't shelter your foreign pension

Portugal's Non-Habitual Resident regime closed to new applicants on 1 January 2024. It was shut by the 2024 State Budget law, Lei n.º 82/2023 de 29 de dezembro, which also created its successor as a new article 58.º-A of the Estatuto dos Benefícios Fiscais. A transitional window let a narrow set of people who had already started relocating in 2023 still register under the old rules, but that window closed on 31 March 2025 and is now exhausted. If you become a Portuguese tax resident today, the old NHR is simply not available to you.

What is open now is IFICI (Incentivo Fiscal à Investigação Científica e Inovação, nicknamed 'NHR 2.0'), operationalised by Portaria n.º 352/2024/1 de 23 de dezembro. It keeps the headline number people remember — a 20% flat rate for ten consecutive years — but only on qualifying Portuguese-source employment or self-employment income (IRS categories A and B), and only if your role sits inside one of six defined routes: higher-education teaching and FCT-certified research, qualified roles in AICEP-recognised productive-investment projects, certain highly qualified professions, positions in R&D-incentivised companies, IAPMEI-recognised activities, and certified startup roles. You must register with the tax authority by 15 January of the year after you become resident, and having lived in Portugal in any of the previous five years disqualifies you.

Here is the input almost every relocation guide skips: IFICI is gated on your activity, not on your residency. There is no blanket foreign-income shelter and, critically, no successor to the old NHR's flat 10% on foreign pensions — pension income is taxed at Portugal's ordinary progressive rates, which reach 48%. So the decisive question is not 'am I moving to Portugal?' but 'does my income come from one of the six qualifying activities?' A retiree living on a foreign pension, or a remote worker whose job falls outside those categories, typically gets neither the 20% rate nor any pension relief.