Just 946 People Have Signed Up for Portugal's Replacement for NHR, and Only One in Nine Is a Teacher or Researcher

Two years after Portugal replaced its non-habitual resident (NHR) tax regime with a narrower incentive for researchers and skilled workers, 946 people have signed up for it. Nine in ten are foreign nationals, two thirds live in Lisbon, and three in four are company managers or IT specialists. Teachers and researchers, the people the scheme is named after, make up about one in nine.

The figures come from the Tribunal de Contas (Court of Auditors), which examined the Incentivo Fiscal à Investigação Científica e Inovação (IFICI, the tax incentive for scientific research and innovation) in its opinion on the 2025 General State Account, published on Tuesday. The court used data from the Autoridade Tributária e Aduaneira (AT, the tax and customs authority), and it warns that the scheme carries control risks similar to those the tax authority saw under NHR. This account is taken from the opinion and from the tax authority's written reply, published in its annex.

How the scheme works

The IFICI was created in the 2024 State Budget, when NHR closed to newcomers. It is open to people who become tax resident in Portugal after at least five years of living abroad, and who work in one of the eligible activities: teaching in higher education and scientific research, highly qualified professions in companies, qualified jobs in sectors that the investment agency AICEP or the business agency IAPMEI consider relevant to the economy, and board positions, for example in certified start-ups.

For ten consecutive years, their Portuguese earnings from those activities, as employees or self-employed, can be taxed at a flat 20 percent, and most foreign income is exempt. In its reply, the tax authority points out that foreign pensions are not part of that exemption. The scheme cannot be combined with NHR, the Regressar programme for returning emigrants, or IRS Jovem, the income tax break for young workers.

Registering is not the same as benefiting. You also have to choose the regime when you file your income tax return. Of the 147 people registered for 2024, only 82 used it that year, the court found; the tax authority says the rest either did not file a return or did not opt in.

Who has signed up

By May 2026 there were 946 registrations: 147 for 2024 and 799 for 2025. The court's profile of them:

• Nationality: 89.3 percent are foreign nationals, from 74 countries. The largest groups are from Brazil (12.1 percent), Russia (10.1 percent), France (7.5 percent), the United Kingdom (7.1 percent), the United States (7.0 percent), Germany (6.4 percent), Portugal (5.9 percent) and Spain (5.1 percent). About half of the Portuguese nationals were born outside Portugal.
• Age: the average is 41. Most (59.2 percent) are aged 36 to 55, and the range runs from 24 to 77.
• Where they live: 65.9 percent have their tax address in Lisbon, followed by Porto (12.0 percent), Setúbal (6.1 percent), Faro (5.3 percent) and Braga (2.5 percent).
• What they do: 75.6 percent are directors and managers or information technology specialists. Company directors, managers and general managers alone make up 24.6 percent of all registrations, and just over half of those certified by IAPMEI. Teaching and research account for 11.3 percent.

The court sees a problem in that mix. The highly qualified professions require a degree-level qualification, but some of the qualified jobs recognised by IAPMEI and AICEP accept post-secondary training below degree level, and some company director posts require no minimum qualification at all. That, it says, "may compromise the goal of attracting highly qualified human capital".

What it costs, and why that is uncertain

Nobody knows yet what the scheme will cost. The government did not estimate its tax cost in the 2024 or 2025 budget reports, which the court says breaches the rule that a new tax benefit needs its cost measured first. The only figure so far covers the 82 people who used it on their 2024 income: 1.5 million euros of lost tax, or 18,642 euros each on average. With registrations up from 147 to 946, the court expects the next figure to be "significantly higher".

It adds a caution about those numbers. The cost is calculated as the tax these people would have paid as ordinary residents, but some might never have moved to Portugal without the incentive, so not all of it is revenue the state actually loses.

For comparison, the old NHR regime cost 2,099 million euros in income tax in 2025, almost two thirds of the cost of all income tax breaks, even though it closed to new applicants in 2024. People already registered keep it for the rest of their ten years. The cost is concentrated: 50 tax returns, 0.1 percent of those claiming it, accounted for 20.2 percent of the total.

The checks, and the risks the court sees

The tax authority checks residence, whether a person is claiming a regime that cannot be combined with the IFICI, and whether their tax affairs are in order. In 2025 and 2026:

• 169 applications were not certified, or were rejected, by the certifying bodies, 15.7 percent of the 2024 applications and 10.6 percent of the 2025 ones;
• 65 were refused by the tax authority, most often because the person was not resident in Portugal, but also because they had NHR, had lived in Portugal in the previous five years, or did not pay Portuguese income tax;
• 16 registered people were identified as no longer meeting the residence rule. The tax authority's reply puts this at 5; the court explains that 5 registrations were suspended in 2025 and 11 more people were recorded as non-resident from early 2026 but were still listed as registered.

The tax authority also missed its 31 March 2026 deadline to tell applicants whether their 2025 registration had gone through. At that date, 73.1 percent of applications, already certified by the relevant body or confirmed by the employer, were still waiting for the tax checks. The authority replied that it carried out those checks at the start of April, and that applicants who met the conditions could see their status as "Inscrito" (registered) on the Portal das Finanças (tax portal) from then.

The court lists four risks, some of which, it says, the tax authority already knows from NHR:

1. Moving income earned in Portugal to another country to claim the foreign income exemption. Under the IFICI, you do not have to prove that foreign income was taxed abroad.
2. People registered as residents who in fact keep the centre of their life in another country.
3. People whose eligible job is confirmed by their own employer, when they own or run that employer.
4. Companies set up mainly so that their managers can use the regime.

The tax authority is now analysing everyone registered to set specific risk criteria for the IFICI, the court says.

A legal question over the job list

The law does not itself define which professions are "highly qualified"; it leaves the list to a government order. The court points to a Constitutional Court ruling from April 2026 on the NHR regime, which found that leaving a similar definition to a government order was unconstitutional in that case. The IFICI list includes "directors of administrative and commercial services", the same job that ruling concerned. The ruling applies only to that case, but the court says it points to legal uncertainty about the scheme.

The scheme will also need amending because the Fundação para a Ciência e a Tecnologia (FCT, the science funding foundation) and the Agência Nacional de Inovação (ANI, the national innovation agency), two of its certifying bodies, have been merged into a new research and innovation agency.

What this means if you use the scheme

Nothing in the opinion changes the rules. The court asks for the incentive's cost to be weighed against what it achieves. If you are registered, check that your status on the tax portal shows as registered, remember to opt in on each year's return, and keep evidence that you live in Portugal and that your job is the one certified. Our guides explain how NHR and the IFICI work.

Source: Tribunal de Contas, Parecer sobre a Conta Geral do Estado de 2025, Box 9 and executive summary, and the tax authority's reply in the annex, published 29 September 2026.