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United Kingdom – Publication: Implications of Ending Portugal’s Non-Habitual Residents Regime

GMS Flash Alert 2023-204 | November 2, 2023

KPMG LLP in the United Kingdom has released an online publication on the Portuguese government's announcement regarding the end of the Non-Habitual Residents regime1 from 1 January 2024 onwards. 

See "The end of an era: Portuguese Non-Habitual Residents regime to end" (30 October 2023).

This publication discusses the impact of this change (from 1 January 2024 onwards) and what this might mean for U.K. resident non-U.K. domiciled taxpayers.

Why this matters

Individuals considering relocating to Portugal will no longer be able to access the special tax regime, unless they meet the relevant conditions and hold a valid residence visa as at 31 December 2023.

This may mean a more burdensome tax situation for employees relocating on assignment to Portugal in future and higher assignment costs for their employers.

KPMG LLP (U.K.) Insights

This announcement was made as part of the Portuguese government’s State Budget Law Proposal for 20242 and, although not yet definite, is highly likely.

The changes could impact taxpayers from jurisdictions other than the U.K. with plans to relocate to Portugal. 

If taxpayers (and their employers) believe they may be affected, they may wish to consult with their qualified tax professionals, KPMG’s Global Mobility Services team in Portugal (partner and country lead Sandra Aguiar (saguiar@kpmg.com)) or, where relevant, a member of the tax team with KPMG LLP in the U.K. (see the Contacts section).

Contacts

Mike Lavan

Director – Global Mobility and Employment Tax

KPMG in the UK

Nicola Sard

Senior Manager

KPMG in the UK

Additional Resources

pdf

Download the PDF


Footnotes

1 For more information on Portugal's Non-Habitual Residents regime, see sections 2.3 and 2.8 of Taxation of International Executives: Portugal, a KPMG International publication. 

2 For the Portuguese budget and related documents, see (in Portuguese) the website for Proposta de Lei do Orçamento do Estado 2024 .


Disclaimer

The information contained in this newsletter was submitted by the KPMG International member firm in the United Kingdom.

GMS Flash Alert is a Global Mobility Services publication of the KPMG LLP Washington National Tax practice. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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