NHR transitional - for existing holders

Grandfathering rules

If NHR was granted to you before the transitional window closed (including the 2024 extensions for certain visa-granted or employment-contract-based residents), you keep the NHR regime for the full 10-year window starting from the year residence was established. The regime does not convert to IFICI automatically.

What stays, what changes

Stays: the 20% flat rate on PT high-value activity, foreign pensions at 10% flat (if granted under old rules), case-by-case treatment of foreign-sourced income under double-taxation treaties. Changes: virtually nothing - the transitional regime preserves the original terms.

Can I switch to IFICI?

Generally no. IFICI has a strict "never benefited from NHR or another special regime" requirement. Keep the NHR you have. If NHR expires (10-year window ends), you revert to the standard progressive IRS (with the Madeira 30% regional differential if resident in RAM).

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