The Portuguese Tax Authorities have recently issued a binding ruling covering several cryptoassets activities to an individual intending to become Portuguese tax resident, while already holding a substantial crypto portfolio accumulated over several years.

A recent Portuguese Constitutional Court decision concerning the former Non-Habitual Resident (NHR) regime has generated significant discussion regarding the 20% flat tax regime and the role of Ministerial Orders in Portuguese tax law. While the decision is technically relevant, its scope remains limited and fact-specific, without invalidating the NHR regime as a whole. Our note outlines the key aspects of the decision, its potential implications, the distinction between the former NHR framework and the current IFICI (“NHR 2.0”) regime, and why principles such as legal certainty and predictability remain central to the Portuguese tax system.

At Kore Partners, we advise international families, entrepreneurs, and investors navigating relocation to Portugal through structured tax and immigration planning. To support informed decision-making, we have prepared three guides covering Portugal’s main residence and tax pathways.

A new Arbitration Court decision (Case 10/2025-T) has taken an unexpected and, in our view, incorrect, turn on how “exemption with progression” applies to NHR investment income. We unpack the case, the reasoning, and why it matters for NHRs.

Portugal Unlocked: A Blueprint for U.S. Citizens is a five-part series by Kore Partners designed to guide Americans through every stage of their Portugal journey.

The United Kingdom and Portugal have signed a new Double Tax Treaty that replaces the 1968 Treaty. The new tax treaty carries real strategic significance. This tax update provides a first overview of the tax treaty.

Portuguese significant amendments to the Nationality Law, materially affect the timeframe and conditions under which foreign citizens can become eligible for Portuguese citizenship.

The Portuguese Appellate Court annulled a personal income tax assessment concerning transfers between different life insurance products within the same insurance company. Kore Partners provides a summary and take.

Portugal’s Central Administrative Court follows the Spanish Supreme Court’s Roche approach on dependent agent permanent establishment — prioritizing economic dependence over formal legal authority.

At Kore Partners, we closely monitor developments in Portuguese tax law, including changes in the interpretation of trust taxation, stamp duty (Imposto do Selo), and cross-border estate planning. This recent tax ruling on cash distributions from foreign trust terminations highlights the evolving approach of the Portuguese Tax Authorities and the potential impact on private clients residing in Portugal. Our international tax team advises on the structuring and liquidation of trusts, asset transfers, and the tax treatment of foreign-held participations and monetary values, ensuring full compliance while optimizing for legal certainty.

In the latest Kore Insight’s we critically look at a ruling that denied the NHR exemption method for income from the UAE based on a presumed case of abuse.

The old NHR transitory rules have finally closed and the new NHR 2.0 is now regulated. The 2024 Budget Law has introduced NHR 2.0 (or IFICI), a redesigned tax incentive replacing the prior NHR regime. This regime offers significant benefits for international professionals and businesses choosing Portugal as their base and has several possible entry points that deserve to be further explored.

If we take crypto capital gains generated as passive income, there several points that are unclear on the tax return and this likely will require clarification from the tax authorities.

Some time ago, we started sharing our selection of business books we put aside to read either in the summer or winter breaks. The link below for our new winter bookshelf.

As year-end approaches, taking some time to review your tax affairs may yield considerable tax savings. This is a summary of 5 Kore tax issues to be aware.

Exchange of (tax) information is a transnational event impacting the crypto-assets, as a whole that is bound to reduce fragmentation and set an initial (international) level playing field.

Update from 28 November 2023: The Parliament has voted the Budget Law and has approved the end of the NHR and grandfathering regime together with a new incentive regime targeting individuals relocating to Portugal and designed to foster scientific research and innovation.

In an era of increased transparency and global financial scrutiny, the exchange of tax information has become a critical process. To address these challenges, it's imperative to advocate for greater clarity, fairness, and streamlined procedures in the exchange of tax information, offering taxpayers a smoother path through this intricate landscape.

Foi entregue no Parlamento a proposta do Orçamento do Estado para 2024 que prevê eliminar o regime dos RNH para novos residentes a partir de 2024.

NHR Update - Draft Budget for 2024 Released