The Portuguese Non-Habitual Resident regime opened to applications in 2009 and was closed to new entrants by the State Budget for 2024, with a transition window for applicants in process running through 31 March 2025. Individuals already enrolled before 31 December 2023 retain the benefit for the balance of their ten-year eligibility period. Everyone else, as of 1 January 2024, is outside the original scheme. The replacement — the Tax Incentive for Scientific Research and Innovation, known by the Portuguese acronym IFICI — was set out in Ordinance 352/2024/1, which came into force on 24 December 2024 with retroactive application to 1 January 2024.
The substantive difference between the two regimes is the eligibility test, and it is the difference that the wealth-migration market is now absorbing. The original NHR offered a flat 20% personal-income tax rate on Portuguese-source employment and self-employment income from a defined list of "high-value-added activities", combined with broad exemption on foreign-source income (pensions excepted after the 2020 amendment, which introduced a 10% rate). The IFICI retains the 20% Portuguese-income rate but ties eligibility to a narrower set of qualifying activities: research positions at universities and approved scientific institutions, teaching in higher education, qualifying roles at start-ups certified by IAPMEI, and certain export-oriented industrial activities approved by AICEP. The retiree, the financial-services principal and the consultancy partner — the three populations that drove the original NHR boom — are, in most cases, no longer eligible.
The structural consequence for the Portuguese property market is now visible. Comporta, the pine-and-rice-paddy coast south of Lisbon that absorbed the Belgian, French and Brazilian NHR inflow between 2017 and 2023, has seen a marked thinning of the buyer pool in the trophy €5m-plus segment through 2024-25. Lisbon's prime residential market — Príncipe Real, Lapa, Chiado — has held better, supported by ongoing Golden Visa demand (the property route closed in October 2023, but the venture-capital and qualifying-investment routes remain open) and by the residual NHR inventory still in the ten-year window. The Algarve trophy segment, anchored on Quinta do Lago and Vale do Lobo, has held on the strength of the British and Irish buyer pool that the NHR change affected less directly.
The redirection of the disappointed flow is the more interesting story for the family-office reader. Italy's flat-tax regime, raised on 30 December 2025 from €200,000 to €300,000 a year for new entrants (with €50,000 per family member added), absorbed a meaningful share of the Portuguese-bound population — Milan and Forte dei Marmi being the principal beneficiaries. Greece's non-dom programme, introduced in 2020 on similar architectural lines to the Italian regime at €100,000 a year, has been a quieter but consistent beneficiary, particularly for buyers who already held property on the Cyclades or in the Peloponnese. Cyprus, with its non-dom regime and 60-day tax-residency rule for individuals not tax-resident elsewhere, has absorbed part of the more mobile cohort. The UAE has captured the largest tranche of those for whom the Mediterranean was a preference rather than a necessity.
What the IFICI does retain — and this is the part the trade press has under-reported — is a usable framework for the specific category of UHNW principal whose income is structured through a holding company conducting qualifying export or research activity. The 20% flat rate on Portuguese-source income, combined with foreign-source exemption on dividends, interest and most capital gains for income generated outside Portuguese-source territory, remains attractive for the founder relocating an operating company or for the academic-track principal returning to Europe. The architecture is narrower than the NHR, but it is not non-existent.
The reading for the buyer who held a Comporta property bought between 2018 and 2022 is mixed. The property as an asset has held its 2023 valuations in most cases; the use case — a tax-efficient ten-year European base — has narrowed. The decision to sell, to hold or to convert to a primary EU residence under the four-year window now depends much more on the buyer's individual fiscal architecture than it did under the original regime, when the answer for almost every UHNW European principal was approximately the same.
Portugal will continue to receive a residential-tourism inflow on the strength of the climate, the coastline and the trophy hospitality stack — JNcQUOI, Sublime Comporta, Sublime Lisboa, the recently announced Aman Comporta in the long pipeline, and the Mandarin Oriental Lisbon planned for the early 2030s. The country will not, however, be the European tax-arbitrage capital that the 2009-23 NHR period made it. That role has moved east, to Italy and the UAE.
— Camille Vedy
