O regime dos residentes não habituais

  • Sara Belo Felgueiras de Santo António (Student)

Student thesis: Master's Thesis


The tax regime of Non-Habitual Residents (RNH) was created in 2009 with the purpose of attracting to Portugal qualified professionals, individuals, and pensioners with high wealth, at a time when the resident population was emigrating. Through the implementation of this regime, in accordance with the memo of the Court of Auditors on the General State Account, which between 2014 and 2022, provides data on the tax expenditure incurred with the NHR regime, Portugal had a total tax expenditure, in the referred years, of around 5,127 Million Euros. The year 2022 alone determined a tax expenditure of €1,360 M, covering 16,371 new taxpayers registered as NHR, bringing the number of taxpayers with access to the regime to 74,258. The NHR influenced the coming of many people to Portugal with the purpose of taking advantage of the tax benefits granted. However, if the data on tax expenditure are partially known, the same does not occur with the revenue generated by the NHRs to the Portuguese State, not only in terms of personal income tax, but also in terms of Property Transfer Tax and VAT. Consequently, this is a win-win situation, otherwise the scheme would not have been in force for fourteen years. This thesis intends to address a set of pertinent issues related to the tax benefit of the NHR, as well as the legal issues inherent to its existence, and the future of the NHR dictated by the State Budget proposal for 2024.
Date of Award5 Feb 2024
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorTomás Tavares (Supervisor)


  • Non-habitual resident
  • Personal income tax
  • High value added activities
  • Double tax treaties


  • Mestrado em Direito e Gestão

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