Yes to (1), and no to (2), but once again - the important bit is your place of stay in PT, i.e. either your escritura if you own a property or your rental agreement if you rent it.
Tax residence is not hard-wired to any āresidence permitā or application for such.
The evil is in details. One can spend less than 183 days in Portugal but still can be a tax resident. However, if one spends over 183 days in Portugal, there is no way to be non-tax resident i.e. he/she must become a tax resident of Portugal. 
I had a really great experience with Andreia Correia at ADA Legal.
Who quickly and efficiently just secured our NHR status within three weeks. We submitted our GV application in March of '23, obviously we have not heard anything back but we wanted to secure our NHR status asap. I highly recommend her to others in a similar situation.
Andreia charges 450Euro per adult and 150Euro per child to register for NHR.
After sitting in on a webinar discussing the issue of NHR eligibility I was concerned that we would not qualify because we donāt even have preapproval yet and voiced my concern to Andreia, her response was:
āWith all due respect to the people that spoke in the webinar you attend to, you are not in a grey area. Your golden visa application, even if you do not have the residency cards yet, allows you to apply to the NHR transitory regime, in accordance with article 236(3)(b)(vi) of the Portuguese State Budget for 2024.ā
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This is wonderful news, and thank you for sharing the resource. 
I have my GV residency card in hand, but donāt have any near term plan to move to Portugal. However, itās a possibility for sure, but probably not for at least 3-5 years. So the idea of getting an apartment simply for NHR is not that appealing. But Iām wondering if there are extremely inexpensive areas of the country where I could rent a tiny place just to have an address, and then apply for NHR based on that. Anyone have any good ideas for that?
There were a flurry of panicked options floating around at the end of 2023 when it looked like there would be a hard deadline for this. We had two offers of ghost leases proposed by lawyers and relocation agents as a means of creating documentation to register for tax and NHR. They were both wildly expensive (circa ā¬500-800 a month IIRC) and typified the fleecing approach many GV actors employ when dealing with us stupid super-rich foreigners against the clock.
You have some time to do this cheaply and properly but you will need somebody on the ground to help you Iād imagine. To change tax address to PT and register for NHR you will need a legal 12-month lease on your rental. Leases are registered with the tax authorities (to avoid landlords evading tax) so this is necessary. Your idea of finding somewhere remote and leasing that is sound. You can search Idealista for this and contact the selling agents. Iād personally be upfront about your requirement and maybe say you will visit PT a few times and want a base so it doesnāt seem too unusual. You may have to pay the lot up front but thatās okay if itās cheap. You can also legally break 12-month leases after six months by giving three months notice (maybe two months, I cannot remember) so your minimum commitment will be 8/9 months rather than the full 12.
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I second @richn4ās suggestion to browse Idealista or similar sites for options. I wasnāt able to search all of Portugal in one go on Idealista, however by drawing the search area I selected approximately half the country at a time.
If itās for a single person (or perhaps even couple) you could consider getting a room in a shared flat instead of a full apartment or house for yourself. In this case you could tell the other tenants that they are welcome to use your room for hosting friends or family from time to time, and Iām sure they would be happy to let you know of any mail or other items that arrive for you.
Here are links to both full homes/apartments and rooms, sorted by lowest rent first, north and south of Castelo Branco:
(Youāll find the cheapest options in the northern half.)
I had no trouble getting NHR at the end of last year even though I donāt have residency yet. A lot of it comes down to where you apply. Some offices ask for additional documentation that is not legally required by the regulations, so you could get rejected and have to fight in court. Others practically rubber stamp it.
I had a tax attorney handle it and they organized an affordable ghost lease for much cheaper than the amounts above, and worked with local counsel in one of the more favorable offices to submit. Went from initial discussion to NHR approved in under a month. The legal cost was ā¬3000eur, but it was painless and I felt it was well worth the cost for 10 years of benefit. Iād be glad to share their info via DM if interested.
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Yes. If you could share the info that would be great!
I seem to have been under a mistaken impression that you need to maintain the residence EACH year to keep the NHR. If you only need to have it when you apply, that is much better!
Can anyone help to explain what will be the implications on PT tax return, after I change my tax residency to PT and register for NHR, but continue to live and work in another country?
Thatās a bit of an open-ended question. Many answers would depend what kind of double-taxation treaty is in-place between your actual country of tax residence and PT.
As I stated above, for U.S. citizens, NHR would practically eliminate almost all taxes if the primary sources of income come from the U.S. The double-taxation treaty with your country of residence will determine how your income is taxed.
Portugalās new finance minister has told FT that the NHR program is coming back with some tweaks. It will still have a 20 per cent flat rate of income tax but only cover āsalaries and professional incomeā and "it will exclude dividends, capital gains and pensions, which was a problem between Portugal and countries like Finland or Swedenā.
Link here (behind subscriber paywall):
Seems reasonable to exclude pensions and cap gains - they want to allow companies to attract foreign talent to work in Portugal. Cap gains you could argue should be included to attract upper management or entrepreneurs, etc, but eh
Wish theyād just lower taxes for everyone but I get it, for various reasons thatās not practical. Sucks for the Portuguese though
Hereās another source (thatās not TPN or paywalled):
Letās see if they can even get majority for the scheme in parliamentā¦
A foreign country taxing a pension from another country never made much sense to me anyway. This is someone who is likely living on a fixed incomeā¦yes, make the amount they have to live on as small as possible for your immigrants!
Another urgency: the availability of NHR. If we donāt become tax residents this year, we lose the NHR benefits, which are significant and for those of us who already stretched financially to do this, essential
While I know it may be possible to declare yourself a tax resident and apply for NHR before actually moving there, I imagine this will create significant tax liabilities in the country youāre essentially depriving of taxes if the declared tax residency doesnāt match with lived reality.
And there are at least some of us who canāt/wonāt emigrate to another country with our loved ones, our pets, and our remaining worldly belongings without having our visas in hand.
For us, this creates a catch-22: 1) Abandon the GVs and hope we still have enough āpassive incomeā and assets (after parking a large portion of our assets in an illiquid āinteriorā PT property) to be approved and lose the time weāve already waited and the freedom to travel that was part of the GV bargain, or 2) keep waiting/suing etc. in hopes we will ultimately be granted the GVs, but lose the benefit of the NHR.
Itās a pretty terrible choice to have to make given that the dilemma was entirely created by PTās failure to make good on itās duty (āshall,ā per the GV statute) to process our applications within 90 days.
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I thought the NHR deadline was Jan 1 2024. Did it extend?
Itās a pretty terrible choice to have to make given that the dilemma was entirely created by PTās failure to make good on itās duty (āshall,ā per the GV statute) to process our applications within 90 days.
This is interesting. My lawyers mentioned that even though the urgent proceeding failed, there is an alternate injunction proceeding we could try, which would require showing:
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SEF has breached its legal duty to act within the legal deadline;
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That such breach is affecting your legal rights;
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And (especially) that this type of Injunction is the only way to prevent your rights from being breached, thus legitimizing the need of an urgent proceeding.
Seems we could meet that?
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The grandfathering is for anyone who started their process (by various means, including by visa application) prior to the cut-off (which I think was Oct. ā23, but donāt quote me on that) AND becomes tax resident by the end of this year (Dec. 31 2024).
I think you can have dual tax residency? The country youāre moving from wonāt mind you getting NHR so long as you continue to file as resident while you are resident there. Then once you move to Portugal you file only as Portugal resident.
Iām not an accountant or lawyer and this isnāt official advice.