On the evening of Monday 2^nd October, Portuguese Prime Minister António Costa during a TV interview, principally on the Budget for 2024, spoke about his government’s intention not to allow the Non-Habitual Tax Residence (NHR) status to continue into 2024. However, this was not an official government announcement and no further details have been released, neither has any draft legislation been circulated.

WHAT WE KNOW SO FAR

Unfortunately, we have very limited information at the moment, based only on the few minutes of the interview which were devoted to the NHR change. However we can say the following.

Provide up to date information on the changes as they occur;

1. Any changes will NOT affect existing NHR registered Portuguese tax residents until the end of the 10-year period
2. The full extent of the legislation is not known. Some of the possibilities are: revocation of the special rate of 20% for professional income generated from high added value activities; revocation of the special rate of 10% for pension income; or revocation of other parts of the NHR legislation. Neither is it know how any changes will be drafted into the current NHR legislation.
3. It is expected that the changes to the NHR legislation will be included into the Budget for 2024. The draft bill will be released on Tuesday 10^th October followed by an extensive period of up of two months of voting and discussions, during which the initial draft is normally changed.
4. Normally the Budget Law enters into force on the 1^st January. This means that it is fully expected that new registrations as NHRs under the current rules will be possible at least until the end of the year.

EDGE – International Lawyers as one of the pioneer law firms advising NHR clients has put together dedicated team which will:

1. Report on how the changes will affect new applicants;
2. Report on the existing NHR programme;
3. Make new NHR registrations using our tailored NHR 2023 service