Portugal’s NHR 2.0: the gift that keeps on giving

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Portugal’s NHR 2.0: the gift that keeps on giving

Sponsored by

sponsored-firm-mlgts.jpg
expo-1107244 (1).jpg

António Queiroz Martins and Carolina Braga Andrade of Morais Leitão, Galvão Teles, Soares da Silva & Associados explore how Portugal’s new non-habitual resident regime is designed to attract top talent through targeted tax benefits

Portugal has recently taken a decisive step in refining its tax regime aimed at attracting qualified professionals, researchers, and entrepreneurs. Known as NHR 2.0, this incentive, officially known as Incentivo Fiscal à Investigação Científica e Inovação (the Tax Incentive for Scientific Research and Innovation), was established through the 2024 State Budget Law and came into effect on January 1 2024. However, it only gained full operability after the publication of Ordinance No. 352/2024/1 on December 23, which clarified its implementation.

A shift from the old NHR regime

The original non-habitual resident (NHR) regime had long been a popular option for foreign retirees, professionals, and high-net-worth individuals. However, the Portuguese government phased out this broader scheme and NHR 2.0 has been introduced in its place as a more targeted regime focused on innovation, research, and national economic impact.

Overview of NHR 2.0

NHR 2.0 offers tax benefits to highly qualified professionals who become Portuguese tax residents, and is applicable for a non-renewable period of ten consecutive years starting from the year of residence registration.

Under this regime, income derived by qualified professionals – either from employment (Category A) or self-employment (Category B) – is taxed at a flat rate of 20%, instead of the general progressive rates (up to 53%). All other Portuguese-sourced income is taxed at the standard general tax rates.

Foreign-sourced income is generally exempt from tax in Portugal, though all worldwide income must be reported to the Portuguese tax authorities. The amount is factored into determining the applicable tax rate on the remaining taxable income, which may be subject to progressive rates (i.e., other than any income exempted or that is taxed at a flat rate).

In contrast with the previous NHR 1.0, foreign-sourced pensions are now taxed at progressive rates, but foreign-sourced capital gains shall be exempted.

Eligible professions and sectors

Unlike the former regime, which was available to anyone who became a resident in Portugal but had not been in the previous five years, NHR 2.0 places a strong emphasis on highly qualified professions and export-orientated businesses, requiring applicants to develop in Portuguese territory one of the following activities:

  • Teaching in higher education and scientific research;

  • Performing qualified jobs or serving as a member of a corporate body within the scope of contractual benefits for productive investment;

  • Carrying out highly qualified activities as defined in the annex to Ordinance No. 352/2024/1 on December 23;

  • Performing another qualified job or serving as a member of a corporate body in an entity carrying out economic activities recognised by the Portuguese Trade and Investment Agency (Agência para o Investimento e Comércio Externo de Portugal) or the Agency for Competitiveness and Innovation (Agência para a Competitividade e Inovação) as relevant to the national economy, particularly in terms of attracting productive investment and reducing regional asymmetries;

  • Working as R&D personnel whose costs are eligible under the corporate R&D tax incentive system (i.e., expenses for personnel with a minimum education level of four in the National Qualifications Framework, directly involved in R&D tasks);

  • Performing any job or serving as a member of a corporate body in an entity certified as a start-up, provided that it complies with certain requirements; or

  • Carrying out jobs or other activities in the Azores or Madeira, under terms to be defined by a regional legislative decree.

Application requirements and verification

Eligibility depends on verification of the requirements regarding the type of activity carried out by the individual, the validation of which is the responsibility of each of the entities to which the applications are submitted (as set out in Ordinance No. 352/2024/1 on December 23), whereas the verification of other legal requirements is the responsibility of the tax authorities.

Final thoughts on the NHR 2.0 regime

Although the NHR 2.0 regime has the potential to attract highly skilled professionals who can contribute to the Portuguese economy – primarily by offering a flat 20% tax rate on qualifying income – it is still relatively new and will require the tax authorities to gain experience and establish a track record in its swift application.

Eligibility decisions are critical, considering that there are different criteria and several application routes. This creates the need for proper planning to overcome administrative hurdles and practical issues that may hinder the full application of the regime.

Further developments are still awaited regarding the publication of the regional legislative decrees by the Azores and Madeira, which will define additional eligible job positions or activities for the application of the NHR 2.0 regime to taxpayers who become tax residents in the autonomous regions. Despite the current uncertainty, these upcoming rules may present a valuable opportunity for professionals seeking to benefit from the regime and relocate to Portugal, and help to attract a talented workforce to the country.

NHR 2.0 represents a positive initiative, reinforcing Portugal’s position as an appealing destination for innovation-driven and high-value professionals. If effectively implemented, it could significantly enhance the country’s scientific and economic ecosystem.

more across site & shared bottom lb ros

More from across our site

The combination between Ashurst and Perkins Coie, which will create a $2.8 bn law firm, is expected to close in Q3
The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office
A co-operative working relationship with the UK tax agency has helped 'unblock entrenched positions' to the benefit of clients, Kara Heggs tells ITR
New hires from rivals are reportedly being axed from the firm, following a steep decline in profits
Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals
Firms announced tax hires and promotions across Europe and the US, while fresh figures from Ireland showed corporation tax receipts edging down in the first quarter
The country has overseen better audit procedures and demonstrated commitment to acting as a 'regional leader' on international tax matters, the OECD said
Barrister Setu Kamal and policy guru Dan Neidle have clashed over the former’s legal action against Google, described as ‘bonkers’ by Neidle
Authors from Khaitan & Co evaluate the recent CBDT notification, whereby legacy investments made by investors continue to be exempt from the applicability of GAAR
Dual-qualified corporate tax specialist Christoph Schimmer joins the firm after stints at Deloitte, Cerha Hempel and DLA Piper
Gift this article