NHR Portugal Closed: Your Realistic Options as a New Madeira Resident

At a glance: The NHR Portugal closed to new entrants on 1 January 2024. The transitional window ended on 31 March 2025. New Madeira residents now have two options: IFICI (the successor to the NHR) if their activity qualifies, or the standard regime with treaty relief. MCS assesses which applies through a fixed-fee €350 diagnostic with a written memorandum.

If you are researching a move to Madeira, much of what you have read about the NHR is out of date. Old guides still promise blanket exemptions and 10 per cent pension rates. Those pages describe a regime that no longer accepts applicants. This article states what closed, what survives, and what your realistic options are.

Key facts

• The NHR was revoked by Lei n.º 82/2023, de 29 de dezembro (confirm against the Affine repository).
• Closed to new entrants: 1 January 2024.
• Transitional window ended: 31 March 2025.
• Existing holders keep their full ten-year term.
• Current successor regime: IFICI.
• IFICI registration deadline: 15 January of the year after residence begins.

When did the NHR close?

The NHR (regime do residente não habitual) was revoked by Lei n.º 82/2023, the 2024 State Budget law. As a result, the regime closed to new entrants from 1 January 2024. A transitional regime then ran through 2024 until 31 March 2025. It covered people who could evidence a concrete 2023 commitment to move: an employment contract, a lease or property contract, school enrolment, or a residence visa in place by 31 December 2023.

That window is now closed. Consequently, there is no route into the NHR for a new arrival in 2026.

Who keeps NHR status?

Existing NHR holders are unaffected. The revocation did not strip acquired rights, so anyone already registered keeps the regime for their full ten-year period. For example, a 2021 registration runs to 2030 under the old rules. If you hold NHR status, your questions concern compliance and the end of your ten years, not alternatives.

Are any transitional cases still open?

Two narrow situations may still deserve professional review:

1. Late registration by someone who qualified. Missed years are not recovered. Where a late registration is accepted, the benefit generally runs only for the remainder of the ten years, counted from the residence year.
2. Pending or disputed registrations. Cases lodged around the deadlines, or refused on evidence, sit in administrative or judicial review. Whether a challenge is viable is a legal question; such proceedings are performed by the lawyers and instructed separately.

For everyone else, the NHR is simply unavailable. Treat any adviser suggesting otherwise as a red flag.

Option one: IFICI, the successor to the NHR

IFICI (the successor to the NHR) is the current inbound regime. It was created by the same law that revoked the NHR. In outline:

• Rate: 20 per cent on eligible employment and self-employment income, for ten years.
• Foreign income: most categories exempt — however, foreign pensions are not, and are taxed at ordinary progressive rates.
• Eligibility: activity-based. It covers defined highly qualified professions, research and higher education, roles in qualifying exporting or certified companies, and a pathway for activities in the Autonomous Regions — directly relevant to Madeira arrivals.
• Deadline: registration by 15 January of the year after residence begins, on evidence.

The honest summary: IFICI is narrower than the NHR, by design. Professionals in qualifying roles can do well under it. Retirees and holders of passive income generally cannot, because the regime was built for talent, not pensions.

Option two: the standard regime with treaty relief

When IFICI does not apply, the baseline is the ordinary Portuguese system plus treaty relief. It is less generous than the old NHR. Even so, it is workable for many people, particularly in Madeira:

• Progressive IRS rates apply to worldwide income. Madeira applies reduced regional brackets compared with the mainland.
• Dividends, interest and most capital gains are taxed at flat autonomous rates, typically 28 per cent. Aggregation remains optional where it produces a better result.
• Treaty relief prevents double taxation. Foreign tax is credited within treaty limits, and some categories, notably government-service pensions under many treaties, remain taxable only in the source state.
• Long-held savings products attract inclusion reliefs, such as reduced effective rates on life-insurance wrappers held past five and eight years.
• Portugal levies no general wealth tax (AIMI applies only to high-value residential property) and no inheritance tax between spouses, descendants and ascendants.

Moreover, two levers exist regardless of regime. First, the timing of residence: income and gains realised before Portuguese residence begins generally fall outside its scope. Second, the allocation choices treaties allow. Sequenced properly before arrival, the standard regime is frequently manageable; sequenced accidentally, it is expensive.

Why is so much online information wrong?

The NHR ran for fifteen years and generated an enormous volume of content with strong search rankings. Rankings outlive accuracy. Pages written in 2022 still outrank pages describing the current law, so new residents keep planning around a regime that closed before they arrived. The fix is simple: check the date on anything you read, and verify the regime it describes still admits applicants.

Frequently asked questions

Is the NHR really closed? I still see websites offering it.

Yes. The NHR Portugal closed to new entrants on 1 January 2024, and the transitional window ended on 31 March 2025. Pages offering it are out of date.

I already have NHR status. Do I lose it?

No. Existing holders keep the regime for their full ten years.

I signed a lease in 2023 but never registered. Is there anything left?

Possibly a narrow late-registration or review question, assessed on evidence. Any litigation is performed by the lawyers and instructed separately.

Is IFICI just the NHR with a new name?

No. IFICI (the successor to the NHR) is activity-based and excludes foreign pensions from exemption. It serves a different population.

I’m retiring to Madeira. What is my realistic regime?

Generally the standard regime with treaty relief: progressive rates on pensions with credit or exemption per treaty, Madeira‘s regional brackets, and flat rates on investment income. Outcomes vary by country.

Does becoming resident in Madeira rather than Lisbon change anything?

Yes, modestly: Madeira applies reduced regional IRS rates and lower VAT, and the IFICI regional pathway may extend eligibility.

Can anything restore NHR-style treatment for new arrivals?

Only new legislation could. Plan on the law in force, not on speculation.

One next step

Before you plan around a regime, or resign yourself to the wrong one, establish which path applies to you. The MCS Eligibility Diagnostic delivers a written memorandum covering your IFICI position, including the Madeira regional pathway, and, where IFICI does not apply, your standard-regime baseline with the steps and deadlines for your case. The fee is credited in full against any subsequent application engagement. Book the Eligibility Diagnostic.

This article is provided for general information purposes only and does not constitute legal, tax or immigration advice, nor does it create any client relationship. Tax regimes, transitional rules and administrative practice change; statements reflect the position understood at the date of writing and items marked for verification must be confirmed at publication. Where a matter requires acts reserved by law to lawyers, including any administrative or judicial challenge, those steps are performed by the lawyers and instructed separately. No action should be taken, or omitted, on the basis of this article without specific professional advice on your particular facts. MCS accepts no responsibility for any loss arising from reliance on this material.