Country Profile
Portugal as a Location: What Remains After the End of NHR
The NHR regime closed at the end of 2024. Its successor, IFICI, only applies to a few professions. Discover what Portugal still offers in terms of tax, where genuine advantages remain, and why many UK expats are now looking elsewhere.
Ended
NHR Regime
20%
IFICI Flat Rate
21%
Corporation Tax
Tax-free
Crypto after 365 days
Fact-based analysis · Based in Malta since 2013
At a Glance
For over a decade, Portugal was the most popular destination for UK expats and international entrepreneurs seeking tax efficiency. The NHR regime, with its flat 20% tax rate on foreign income, made the country highly attractive to freelancers, retirees, and investors alike. Since the end of 2024, this programme has been closed. Its successor, IFICI, is aimed exclusively at qualified professionals in defined sectors such as science, technology, and healthcare, requiring at least an EQF Level 6 qualification. For entrepreneurs, investors, and digital independents, the IFICI regime is not an option. What remains is a solid quality of life, a functional visa system, and a surprisingly attractive crypto tax regime. However, standard tax rates are at a level that leaves little room for tax-motivated relocation.
Eckdaten im Überblick
| Corporation Tax (IRC) | 21%Effectively up to 31.5% with Derrama and Derrama Estadual |
| Income Tax (IRS) Top Rate | 48%Progressive, with solidarity surcharge over 50% possible |
| IFICI Flat Rate | 20%Only for professionals in science, tech, health, renewables |
| NHR Status | EndedNew applications closed since late 2024, transition until March 2025 |
| Crypto Holding Period Tax-Free | 365 daysCapital gains tax-free after one year of holding |
| Golden Visa Minimum | EUR 500,000Only via qualifying investment funds, real estate route restricted |
| DTT with the UK | ActiveDouble taxation treaty in place with the United Kingdom |
| EU Member | YesFull access to the EU single market since 1986 |
Why Portugal attracted UK expats for years
Portugal was the most obvious European destination for many UK expats. A mild climate, low cost of living, a growing expat community in the Algarve and Lisbon, plus a time zone that made working with UK clients straightforward. That alone would have generated solid interest.
But what made Portugal the most discussed relocation destination was the NHR (Non-Habitual Resident) regime. Since 2009, new arrivals who had not been tax resident in Portugal in the previous five years could benefit from a flat 20% income tax rate on certain Portuguese income. Foreign income such as dividends, royalties, and pensions from non-blacklisted countries often remained completely tax-free or were taxed at a flat 10% under the NHR.
For UK retirees, this made Portugal significantly more tax-efficient than staying in the UK for years. For freelancers with international clients, investors with dividend income, and digital nomads, the NHR regime offered a legal way to substantially reduce their tax burden. UK financial advisers and international tax consultants routinely recommended Portugal as a top choice.
In October 2023, the Portuguese government announced the end of the NHR. New applications were possible during a transition period until March 2025. Since then, the programme has been closed. Existing NHR holders retain their status until their individual ten-year period expires, but the NHR no longer exists for new arrivals.
The tax model after NHR
Without the NHR, standard tax rates apply in Portugal. Income tax (IRS) is progressive, ranging from 14.5% to 48%. A solidarity surcharge of up to 5% applies to the highest income brackets, pushing the effective top rate to over 50%. For high-earning entrepreneurs, this is a significant factor.
Corporation tax (IRC) is 21%. On top of this, there are municipal surcharges (Derrama) of up to 1.5% and a state surcharge (Derrama Estadual) for profits over EUR 1.5 million. The effective total burden can therefore rise to up to 31.5%. SMEs with an annual profit below EUR 25,000 benefit from a reduced rate of 17% on the first bracket of profit.
Capital gains and investment income are generally taxed at 28%. Taxpayers can alternatively opt for assessment at the progressive rate, which can be more favourable if their total income is low. Dividends from Portuguese companies are also subject to a 28% withholding tax.
A notable exception is the taxation of cryptocurrencies. Portugal does not tax capital gains from crypto assets held for more than 365 days. This rule has been in place since the 2023 tax reform and is unusually generous by international standards. For crypto investors with a long-term horizon, Portugal remains an attractive location, even without the NHR.
The NHR successor, IFICI (Incentivo Fiscal à Investigação Científica e Inovação), offers a flat tax rate of 20% on qualifying income. However, eligibility is strictly limited: the programme is aimed exclusively at professionals in science, technology, healthcare, and renewable energy. An academic degree of at least EQF Level 6 (Bachelor's) is required. Entrepreneurs, investors, retirees, and digital independents not working in these defined sectors are excluded.
Without the NHR, Portugal's standard taxation is above the European average. The crypto rule after a 365-day holding period is the only remaining tax advantage with broad applicability.


Residency and Visas
As an EU member, Portugal offers free movement to EU/EEA citizens. For UK nationals post-Brexit, the situation is different. While EU citizens only need to register with the local municipality (Câmara Municipal) and the Autoridade Tributaria (Portuguese Tax Authority), UK citizens must apply for a visa. Tax residency generally begins after spending more than 183 days per calendar year in the country.
For non-EU citizens, including UK nationals, several visa categories are available. The D7 Visa (Passive Income Visa) is aimed at individuals with verifiable passive income and is particularly popular with retirees and remote workers. It requires proof of regular income, health insurance, and a residential address in Portugal. After five years of residence, you can apply for permanent residency or Portuguese citizenship.
The Golden Visa programme still exists but was significantly restricted in 2023. The classic route via real estate investment is no longer possible in most regions. What remains is the fund option, requiring a minimum investment of EUR 500,000 in qualifying Portuguese investment funds. The administrative burden has increased, and processing times have lengthened.
For non-EU nationals with an entrepreneurial spirit, there is also the Tech Visa and the D2 Visa (Entrepreneur Visa). Both require a concrete business plan and proof that the planned activity will contribute to the Portuguese economy.
“Many of our clients had Portugal as their first choice. Since the end of the NHR, they come to us with a specific question: is there an EU alternative with a comparable quality of life but active tax programmes? Malta is that alternative.”
Dr. Jörg Werner
Founder, Dr. Werner & Partners
Reality Check: Everyday life for UK expats
The cost of living in Portugal is well below UK levels. While Lisbon and Porto have become noticeably more expensive in recent years, they remain cheaper than London or Edinburgh. In the Algarve and inland, rent, groceries, and services are significantly lower again. For expats who don't need to be in a major city, the cost structure is one of the strongest arguments for Portugal.
The international expat community in Portugal is large and well-connected. Over the years, networks, English-speaking service providers, and information channels have established themselves in the Algarve, Lisbon, and Cascais. If you're looking to connect, you'll find it relatively quickly. However, this community largely keeps to itself. If you want to integrate into Portuguese society, you need to speak Portuguese.
And this is an often-underestimated point: the official language is Portuguese. Dealings with authorities, tax matters, tenancy agreements, and bank correspondence are all in Portuguese. Many younger people in Lisbon speak English, but when dealing with the tax office, social security, and local authorities, language skills or a local advisor are essential. This fundamentally distinguishes Portugal from locations like Malta, where English is an official language.
Portuguese bureaucracy has a mixed reputation. Digital services like the Portal das Finanças are generally functional but slow and sometimes only available in Portuguese. Processing NIF (tax number) applications, social security registrations, and residence permits can take several weeks. Flexibility and patience are required.
Climatically, Portugal is hard to beat. Over 300 days of sunshine a year, mild winters, and one of the longest coastlines in Europe. For expats where quality of life plays a major role alongside tax considerations, Portugal remains a first-class location. The only question is whether the tax side still adds up after the end of the NHR.


Assessment: How Malta differs
Portugal and Malta share some similarities: both are EU members, both have a mild climate, and both are popular with UK expats. But in terms of tax and structure, they are in very different positions following the end of the NHR.
Malta's refund system lowers the effective corporation tax to 5%. This system has been established for decades, is EU-compliant, recognised by the OECD, and has never been called into question. In Portugal, the standard corporation tax is 21%, with surcharges pushing it up to 31.5%. For entrepreneurs with an active business, this is a substantial difference.
At the individual level, Malta offers the FITWI (Flat-rate Income Tax for Worldwide Income) regime, with a flat rate of 15% on worldwide income remitted to Malta. Unlike IFICI, this programme is not restricted to specific professions or sectors. It is generally open to entrepreneurs, investors, retirees, and digital independents who meet certain minimum requirements.
A practical advantage that is often overlooked: English is an official language in Malta. All government processes, contracts, banking discussions, and tax returns are conducted in English. This significantly reduces reliance on local translators and intermediaries, making daily administration much easier for international expats.
Malta's active double tax treaty with the UK (SI 1995/763) provides clear allocation rules and protection against double taxation. Portugal also has a DTT with the UK, but since Portuguese standard tax rates are higher, the practical advantage is smaller.
This is not meant to be a blanket judgement. Portugal is an excellent place to live in many respects. If you are looking for a lower cost of living, prefer the Atlantic climate, and tax optimisation is not your primary motive, you can live exceptionally well in Portugal. But for expats where the tax structure is a central factor, the baseline has fundamentally changed since 2024.
Malta's programmes are industry-independent and active. Portugal's NHR has ended, and its successor, IFICI, only applies to professionals in defined sectors.
IFICI in detail: Who the NHR successor works for
The IFICI regime (Incentivo Fiscal à Investigação Científica e Inovação) was introduced in 2024 as the successor to the NHR. The name itself reveals its direction: it is about science and innovation, not broad tax-driven location policy. The programme offers a flat income tax rate of 20% on qualifying income for a period of ten years.
Eligibility criteria are strictly defined. Applicants must not have been tax resident in Portugal in the previous five tax years. They must work in one of the approved sectors: scientific research, technological development, healthcare, renewable energy, and related fields. An academic degree of at least EQF Level 6 (Bachelor's or equivalent) is required.
What this means in practice: a software developer with a computer science degree employed by a Portuguese tech company can benefit from IFICI. An entrepreneur running their own holding company, an investor with dividend income, a retiree, or a professional poker player cannot. Freelancers and remote workers who are not active in one of the defined sectors also fall through the cracks.
For the UK entrepreneurs and expats who made the NHR popular, IFICI is therefore largely irrelevant. It is a skilled worker recruitment programme, not a functional successor to the NHR. Anyone looking for a tax-efficient EU solution as an entrepreneur, investor, or digital independent today must consider other locations.
Our Process
Free Initial Consultation
We analyse your current situation, clarify the tax implications of leaving the UK, and assess whether Malta is the right alternative to Portugal for your profile.
Tax Structuring
Together, we design the optimal corporate structure in Malta: holding, operating company, refund setup. Tailored to your individual situation and target markets.
Company Formation in Malta
We guide you through the entire formation process: articles of association, registration, tax registration, and bank account opening. Timeframe: 6 to 8 weeks.
Relocation and Residency
Organising your change of residence: residence permit, registration, social security arrangements, and finding a home. Everything from a single source.
Ongoing Support
Bookkeeping, annual accounts, tax returns, and refund applications. We remain your point of contact for all tax and legal matters in Malta.
Were you considering Portugal? Let's explore whether Malta is the better alternative for you.
In a free initial consultation, we analyse your situation and show you which tax structure in Malta is possible for your profile. Honest, confidential, and with no sales pressure.
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Gründung Ihrer maltesischen Gesellschaft inklusive Steuerstruktur, Bankkonto und Registrierung.
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Steuerliche Strukturierung für DACH-Unternehmer mit internationaler Ausrichtung. DBA-Optimierung, Refund-System, Wegzugsbesteuerung.
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Frequently Asked Questions
Transparency matters to us. Here you will find answers to the most common questions on this topic.
No. The NHR regime was closed to new applications at the end of 2024. The transition period ran until March 2025. Individuals who obtained valid NHR status before the deadline retain it until the end of their individual ten-year period. For everyone else, standard Portuguese tax law applies with progressive rates up to 48%.
In most cases, no. IFICI is aimed exclusively at qualified professionals in defined sectors such as science, technology, healthcare, and renewable energy. An academic degree of at least EQF Level 6 is required. Independent entrepreneurs, investors, retirees, and digital independents not working in these fields are not eligible.
Partially. Capital gains from crypto assets held for more than 365 days are tax-free in Portugal. Short-term gains (held for less than a year) are taxed at 28%. Mining income and staking rewards can be classified as commercial income and are then subject to progressive income tax rates.
Malta's FITWI (Flat-rate Income Tax for Worldwide Income) regime offers a flat tax rate of 15% without sectoral restrictions. It is open to entrepreneurs, investors, and digital independents. Portugal's IFICI is restricted to professionals in science, tech, and health with at least an EQF Level 6 degree. For most UK expat profiles, Malta's programme is much more broadly applicable.
Yes, but in a restricted form. The classic real estate route was closed in most regions in 2023. What remains is the fund option, requiring a minimum investment of EUR 500,000 in qualifying Portuguese investment funds. Processing times have lengthened, and the requirements for fund selection have become stricter.
Next step
Were you considering Portugal? Let's explore whether Malta is the better alternative for you.
In a free initial consultation, we analyse your situation and show you which tax structure in Malta is possible for your profile. Honest, confidential, and with no sales pressure.

Dr Jörg Werner
Founder & Lawyer




and his team in Malta
