With the OE2024 proposal, the eligibility rules for the NHR tax regime change, with this program – which allows non-residents who move to Portugal to benefit from a 20% IRS rate – now covering people who earn income resulting from careers in higher education and scientific research teachers.

Income resulting from PhD research and development jobs is also eligible. As with the NHR still in force, they can benefit from the aforementioned 20% IRS rate for 10 years, and for this purpose they cannot have been tax residents in Portugal for the previous five years.

The type of eligible professions is one of the major differences compared to the current model – and for which people who, on December 31, 2023, meet the criteria required to be NHR or hold a visa, can still register until March 31, 2024.

In the model still in force, non-residents (foreigners or emigrants moving to Portugal can join the regime directly, as long as they have one of the professions on the list of professions considered to have high added value and which is defined by ordinance. For those tax experts consulted by Lusa, the new tax regime aimed at non-habitual residents will not be able to attract people to Portugal.

“The regime [created in the budget proposal] is completely ineffective in attracting anyone”, says inspector Luís Leon, from the consultancy Ilya, adding that, if it is not changed during the discussion, it will be “useless” since it is very limited”.

For Patrick Dewerbe, from the tax practice area at CMS Law, the elimination of the NHR constitutes “a blunder”, considering that the new regime “is not attractive at all” taking into account the type of professions and jobs covered.