Portugal NHR Transitional Rules: 2023–2024 Cases and Late Filing
Last updated: September 11, 2026 By E-Residence Team
Portugal’s ordinary NHR route was repealed from 1 January 2024. This page is only for people whose status or documented commitments may place them inside the statutory transitional regime. If you first became a Portuguese tax resident in 2025 or later, these rules do not provide a route into NHR.
In short
- Existing NHR beneficiaries keep the regime until the end of their individual 10-year period.
- A person who met the Portuguese tax-residence conditions on 31 December 2023 belonged to a different transitional category from a person who became resident during 2024.
- The 2024-resident route required one of the elements listed in Article 236.º, including, depending on the case, an eligible commitment or a visa/residence-permit procedure initiated by the applicable date.
- A late application by a qualifying 2024 resident does not create a new 10-year period; if accepted, it covers only the years remaining through 2033.
Which group are you checking?
| Situation | Current position and critical date |
|---|---|
| Already registered as NHR on 1 January 2024 | The regime continues until the end of the original 10-year period; keep evidence of the registration and starting year. |
| Met Portugal’s tax-residence conditions on 31 December 2023 | Registration with effect from 2023 could be requested through the Portal das Finanças by 31 March 2024. Do not assume the separate late-filing rule for qualifying 2024 residents applies. |
| Became tax resident by 31 December 2024 and had a qualifying 2023 commitment | The 2024 transitional route could apply, subject to the statutory facts and evidence. Registration with effect from 2024 was due by 31 March 2025; both the commitment date and residence date matter. |
| Member of the tax household of a qualifying person | The route may also apply if the household member became resident by 31 December 2024 and the statutory conditions are met. “Household member” is broader than spouse alone; verify the household facts with AT. |
Qualifying commitments for the 2024-resident route
The law refers to pre-existing links to Portugal, not to a general intention to move. Depending on the category, the relevant evidence includes:
- an employment contract, promise of employment or secondment agreement requiring work in Portugal, concluded by 31 December 2023;
- a residence visa or residence permit valid on 31 December 2023, or a qualifying visa/permit procedure initiated by that date;
- a lease or another agreement granting use or possession of Portuguese property, concluded by 10 October 2023;
- a reservation or promissory contract to acquire a right in rem over immovable property in Portugal, concluded by 10 October 2023;
- enrolment of a dependent in a Portuguese educational establishment by 10 October 2023.
These are statutory categories, not a promise of approval. The Tax Authority can require proof that the exact dates and conditions are met.
What late filing changes
For a qualifying person who became resident in 2024, filing after 31 March 2025 does not restart the clock. If the late request is accepted, the regime takes effect only from the year of registration and ends at the close of the original 10-year window counted from 2024.
For example, an accepted registration made in 2026 would cover 2026–2033, not 2026–2035. This late-filing mechanism should not be presented as a new NHR opportunity for someone who arrived in 2025 or 2026.
Next step
This page does not reproduce NHR benefits or explain IFICI. For the current overall position, read the complete guide to Portugal’s NHR and IFICI rules and compare your evidence with the Tax Authority’s current guidance. Individual tax outcomes require case-specific professional advice.
Information checked against official sources on 11 September 2026.