For a decade the Iberian comparison was simple: Portugal's NHR beat everyone for foreign-source passive income, Spain's Beckham beat everyone for high-salary executives. Portugal closed NHR to new applicants in Q4 2023. The replacement régime (IFICI) is so narrow that for most inbound HNW the choice is now between Spain Beckham and full Portuguese tax. The math has flipped, and most relocation advisors are still quoting the old version.
Old NHR (closed October 2023): Portugal taxed foreign-source dividends, interest, and capital gains at 0% for ten years. Spanish-source equivalents under Beckham were taxable at standard rates. Portugal won decisively for retirees and HNW with foreign passive income.
Post-NHR Portugal (current state for new arrivals 2024+): The replacement IFICI (Incentivo Fiscal à Investigação Científica e Inovação) is restricted to scientific research, innovation, and a narrow list of qualifying professions. Most retirees, founders, and inbound executives are now subject to standard Portuguese IRS — progressive to 48% on income, 28% flat on dividends and interest, 28% on capital gains.
Spain Beckham (current 2026): 24% on Spanish-source employment income up to €600K, 47% above. Foreign passive income (dividends, interest, capital gains, foreign rentals) — exempt. Foreign employment income — taxable. Six tax years of régime access.
The crossover: For an HNW arrival with significant foreign passive income, Spain Beckham now beats post-NHR Portugal by roughly €100,000-200,000 per year on a €500K-1M passive-income profile. Portugal D7 still wins on visa processing speed (3-6 months vs 9-15 for Spanish digital nomad) and on the 5-year citizenship pathway (vs 10 years in Spain). Choose Spain for tax, Portugal for passport.
Portugal's Non-Habitual Resident régime, in force since 2009, was closed by Lei 82/2023 do Orçamento do Estado para 2024. New applications closed 31 December 2023. Existing NHR holders continue under the old terms for the remainder of their 10-year window. There is no grandfathering for new arrivals after 1 January 2024.
The replacement, IFICI, is defined in Article 58.º-A do CIRS (Estatuto dos Benefícios Fiscais reformulated). It is restricted to:
The régime offers a 20% flat IRS rate on Portuguese-source income from qualifying activity — but the foreign-source dividend, interest, and capital-gains exemption that defined old NHR is not part of IFICI. Foreign passive income is now taxed at standard Portuguese rates for IFICI beneficiaries, with the only relief being that pensions remain tax-free if covered by a DTC (and even that is being reviewed).