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What Portugal's 2025-2029 Tax Plan Proposes Vs Enacts
Portugal's government published a programme for 2025-2029 that includes tax-related policy signals. This guide explains what the plan actually says about NHR, IFICI, and broader tax policy, what it does not say, and how to think about it without over-reacting to political signals.
Headlines suggesting "NHR is coming back" oversimplify what is a political programme, not a legislative act.
What The 2025-29 Government Plan Actually Says
Among its main measures, the programme commits to cutting IRS by EUR 2,000 million over the parliamentary term, EUR 500 million of it in 2025, especially for the middle class, and to reviewing and rationalising tax benefits. It also speaks of retaining talent and attracting investment, but it does not mention NHR or IFICI.
In practice, a government programme is a statement of intent. It is not legislation. It does not create rights, obligations, or new regimes. Between a programme statement and an applicable law, there are multiple legislative and regulatory steps.
Is Portugal Bringing Back NHR?
The short answer: not in its original form, and not through this programme alone.
The programme speaks of retaining talent and attracting investment, but it proposes no specific regime. Any change to IFICI, a new incentive regime or a change to the existing rules depends on future legislation.
Planning based on what a government programme may become is speculative. Planning based on what the law currently is remains the professional standard.
What The Plan Signals About IFICI
IFICI succeeded NHR as the main tax incentive for new residents engaged in qualifying activities. The government programme does not mention IFICI, so it neither revokes nor replaces it.
For taxpayers currently in the IFICI application process or already registered, nothing in the programme changes your current obligations or treatment. For details on IFICI eligibility and application, see our IFICI practical guide.
Broader Tax Policy Signals
Beyond NHR and IFICI, the programme touches on several areas relevant to expats and cross-border taxpayers:
IRS rates. The rate table in CIRS art. 68 has already been changed twice: by Lei n.º 55-A/2025 of 22 July and by the State Budget for 2026 (Lei n.º 73-A/2025 of 30 December). Any further change needs a new law.
Social security. References to contribution framework review, which could affect self-employed and business owners.
Investment incentives. Broader language about attracting foreign direct investment and entrepreneurship.
Real estate taxation. References to housing market measures that could affect property owners and landlords.
Each of these requires specific legislative implementation before it changes any taxpayer's position.
How To Think About Government Programmes
Programme published
Political intent, not law.
State Budget proposed
Specific measures drafted for the annual budget.
Parliamentary approval
Budget voted on and potentially amended.
Publication in Diário da República
Becomes law.
Administrative guidance
Tax authority publishes implementation rules.
Until step 4, nothing changes your filing position. Even after step 4, the effective date and transitional provisions matter.
Monitor developments, but do not make planning decisions on headlines.
What This Means For Your Tax Planning
If you are currently planning a move to Portugal, already resident, or in the middle of regime-related decisions:
Plan under current law.
IFICI is the available framework now.
The State Budget for 2026 (Lei n.º 73-A/2025, published 30 December 2025, in force from 1 January 2026) has since been enacted. It did not reintroduce NHR or restructure IFICI: IFICI remains the active framework for new arrivals, and NHR remains closed to new applicants apart from the transitional cases in Lei n.º 82/2023, art. 236. Continue monitoring future budgets, since the government's stated multi-year plan could still resurface in a later one.
Document your positions based on current rules. If rules change, you adjust from a documented baseline.
Comparison: NHR Vs IFICI Vs Potential Future Framework
| Feature | NHR (Repealed for New Entrants) | IFICI (Current) | Future Framework (Speculative) |
|---|---|---|---|
| Eligibility | New residents, 5-year non-residency | Activity-dependent, entity validation | Unknown |
| Income Scope | Foreign + Portuguese qualifying income | Qualifying category A and B activity income, plus foreign-source A, B, E, F and G income exempt with progression (CIRS art. 81(4)) | Unknown |
| Duration | 10 years | 10 years | Unknown |
| Tax rate | Former NHR: 20% on specified Portuguese Category A or B income, with category, source, treaty, and anti-abuse conditions for foreign-income relief | IFICI: 20% on eligible Portuguese Category A or B activity income | Unknown |
| Status | Closed to new entrants from 1 January 2024, except the transitional cases in Lei 82/2023, art. 236(3) | Active for eligible taxpayers (EBF art. 58-A) | Do not rely on a future framework until legislation is enacted |
Scroll or use the arrow keys to compare all columns.
Primary Sources
These official sources are the starting point for checking current rules before applying them to a client fact pattern.
- Governo de Portugal: Programme of the XXV Constitutional Government
- Portuguese Budget portal (oe.gov.pt): Grandes Opções 2025-2029
- portugal.gov.pt: IRS Jovem 2025 explainer
- Governo de Portugal: housing tax measures
- Diário da República: Lei n.º 73-A/2025, de 30 de dezembro (Orçamento do Estado para 2026)
- AT: CIRS article 81 and transitional provisions
Portuguese tax outcomes depend on dates, documents, elections, source country rules, and the exact income or asset involved.
Frequently Asked Questions
Is NHR coming back in 2026?
The former NHR regime was revoked from 1 January 2024, subject to statutory transitional rules. IFICI is the current incentive under Article 58-A of the Tax Benefits Code. Government programmes and announcements are not law; check enacted legislation and eligibility at the date of action.
Should I wait to move to Portugal until a better incentive is available?
That is a personal decision, but from a tax planning perspective, delaying based on speculative future benefits is usually not productive. Plan under current rules and adjust if legislation changes.
Does the government plan affect my existing NHR or IFICI status?
A government programme does not itself change the law. NHR or IFICI treatment depends on the legislation applicable to the tax year, transitional provisions and continuing eligibility. Registration does not freeze every future tax rule.
When will we know if anything actually changes?
The most likely vehicle for concrete changes is the annual State Budget. The State Budget for 2026 (Lei n.º 73-A/2025) was published 30 December 2025 and took effect 1 January 2026; it did not reintroduce NHR or restructure IFICI. Continue monitoring future budgets for further developments.
