NHR 2.0 - Discussion and Optimization

I’m also starting to see articles admitting that NHR 2.0/IFICI isn’t all sunshine and roses - like this one:

TPN/Lusa, 20-Feb 2025 - “Tax regime for new residents criticised”

  • JoĂŁo MagalhĂŁes Ramalho, from the Tax Department of Antas da Cunha Ecija: registration with IFICI depends on several requirements, such as the profile and nature of the employers’ activity, the taxpayer’s academic and professional history, and the nature of the profession to be exercised. “Furthermore, the right to be taxed by the IFICI depends, each year, on the taxpayer continuing to earn income resulting from the exercise of the relevant activities (the interruption cannot be longer than six months)”
  • LuĂ­s Leon, from the consultancy Ilya, also points out the fact that IFICI requires a "double criterion - eligible employer and eligible profession - making it “much more restrictive”, in addition to excluding all retirees.
  • …At the same time, he says, there is less than a month left for people to be able to sign up [for 2024], but the platform for this does not yet exist. [OMG this is sooo Portugal! :man_facepalming:]
  • Patrick Dewerbe, from Pena & Arnaut Advogados, also has reservations: "15 years after the approval of the RNH, we have gone from a simple and easy-to-apply regime to a regime that is complex and difficult to explain to potential candidates."