Wealth Structuring

Tax Advisory

International tax advice organises your tax burden lawfully, anticipating the impact of changing residence, investing or inheriting abroad. The goal is compliance: paying what is due, where it is due, with no surprises and no risk.

How it works

Analysis of tax residence (generally over 183 days or habitual residence) and its consequences.
Assessment of applicable regimes, such as IFICI in Portugal, and of double-tax treaties.
Planning the move, the investment or the succession, with reporting obligations in each country.

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Legal framework

Portugal: the former Non-Habitual Resident (NHR) regime was closed and replaced by IFICI (Law no. 82/2023; Article 58.º-A of the EBF; Ordinance no. 352/2024/1), with a special rate for qualified activities.
Double-tax treaties between Portugal, Brazil and other countries.
Automatic exchange of information (CRS). Regimes change often — we always confirm the text in force.

In depth

From NHR to IFICI

For years, Portugal attracted residents with the Non-Habitual Resident (NHR) regime. That regime was closed to new entrants and replaced by IFICI (Tax Incentive for Scientific Research and Innovation), created by Law no. 82/2023 and regulated by Ordinance no. 352/2024/1.

IFICI is narrower: it targets qualified activities (research, innovation, higher education and highly qualified roles), with a special rate on eligible income. Unlike the NHR, foreign pensions no longer receive a benefit. Those who already held NHR keep it for the granted period.

Tax residence and double taxation

Tax residence — as a rule, more than 183 days in a country or having habitual residence there — determines where your worldwide income is taxed. Moving country without planning tax residence is one of the main sources of problems.

Double-tax treaties (such as the one between Portugal and Brazil) and tax credits avoid paying twice on the same income, provided the planning is well done and the reporting obligations met.

Frequently asked questions

Does Portugal's NHR regime still exist?

Not for new entrants: it was replaced by IFICI in 2024, which is narrower and aimed at qualified activities. Those who already held NHR keep it for the granted period.

What is IFICI?

It is the Tax Incentive for Scientific Research and Innovation (Law 82/2023), the successor to the NHR, with a special rate for income from qualified activities over a period set by law.

Will I pay tax twice if I move country?

Generally no: double-tax treaties and tax credits avoid it, provided the planning is well done.

When do I become tax resident in another country?

As a rule, by staying more than 183 days there or having habitual residence there. Rules vary and should be confirmed case by case.

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