NHR changed. But the challenge is the same: proving you really live in Portugal.
The Non-Habitual Resident (NHR) regime closed on 1 January 2025 and was replaced by IFICI (known as NHR 2.0). The benefits change, but not the underlying risk: if you move to Portugal, Spain's Tax Agency can require you to prove that you really spent more than 183 days outside Spain. And the Portuguese certificate alone is not enough.
GeoNotary produces that proof: a continuous, automatic expert record of your physical presence, with court validity.
Portugal tax facts
| General income tax (resident) | progressive, up to ~48% |
| Tax-residence threshold | 183 days/year (or habitual home) |
| Regime for new residents | IFICI / NHR 2.0 |
| IFICI — qualified employment income | 20% flat (strategic sectors) |
| IFICI — foreign income (dividends, etc.) | exemption (with conditions) |
| IFICI duration | 10 years |
Indicative figures as of 2026. IFICI is a recent regime with strict requirements; consult an adviser before making decisions.
From NHR to IFICI: what changed in 2025
Original NHR (closed in 2025)
Broad and flexible: simply being a Portuguese tax resident was enough to enjoy benefits on almost any kind of income, including retirees and digital nomads. Anyone already granted it keeps it until their 10 years run out.
IFICI / NHR 2.0 (in force)
Selective and strategic: 20% flat on qualified employment income in strategic sectors (science, technology, health, energy) and exemption on most foreign income. Requires being a new resident (not resident in the last 5 years) and a link to those sectors.
Many profiles that fit the old NHR (retirees, generic digital nomads) no longer benefit from IFICI. Check your eligibility before moving.
The real risk: a Spanish tax inspection
Spain's Tax Agency applies the tests in article 9 of the Personal Income Tax Act (Law 35/2006), independent of each other — meeting just one is enough:
- 1
Permanence > 183 days: your sporadic absences count as days in Spain unless you prove tax residence in another country with a certificate valid under the tax treaty.
- 2
Centre of economic interests: if your business, income or main assets remain in Spain.
- 3
Family nucleus: if your non-separated spouse and minor children reside in Spain.
The tax debt becomes time-barred after 4 years and the move may trigger the exit tax (art. 95 bis of the Income Tax Act) on latent capital gains. An unfavourable reassessment with high income easily exceeds €300,000. Portugal's proximity (a land border with no controls) makes the real day count especially hard to document with traditional evidence.
Why traditional evidence isn't enough
- Tickets and travel: Portugal and Spain share an uncontrolled land border; there is no record of your crossings.
- Utility bills: prove consumption, not the holder's personal presence.
- Card statements: prove use, not that you used it in person.
- Certificate and town-hall registration: party-issued documents, open to challenge.
- Google Maps Timeline: rejected by the tax authority because it is editable by the user.
How GeoNotary solves it
- Continuous, automatic location record: covers all 365 days, with no gaps — key when there is no border control.
- Biomechanical verification of the carrier: confirms it was you carrying the device.
- Public blockchain sealing + eIDAS timestamp: an unalterable, verifiable record.
- Expert report: admissible before the tax authority, the Economic-Administrative Tribunals and the administrative courts.
Unlike daily-selfie check-in apps, GeoNotary doesn't rely on you remembering to register each day, nor does it leave the days you forget without proof: it records continuously and silently, and certifies who was carrying the device — not just that a phone was somewhere.
Frequently asked questions
Start proving your residence in Portugal today
The proof is preventive: the sooner you install it, the stronger your defence.
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