Is tax residence the same as a residence permit?

No. A residence permit is an immigration title; tax residence is the criterion that defines where you are taxed. You can have one without the other.

Can I be a tax resident in two countries at once?

It can happen if two countries' rules consider you resident. In that case, the double taxation treaty, where one exists, defines the relevant residence and how overlap is removed.

Is the NHR regime still available?

The classic regime was closed to new applicants and replaced by a more restricted incentive (IFICI). Conditions and deadlines should be confirmed in the framework in force.

When should I deal with tax residence?

Before moving country. Prior planning opens options that disappear once the move is done.

International tax residence: what changes when you move

There is a question that should come before any international move and yet is usually left to last: where will I pay taxes? The answer depends on a central and often misunderstood concept — tax residence. Understanding how it works is what separates a smooth move from a series of unpleasant surprises.

What tax residence is

Tax residence is not the same as holding a visa, an address or even a residence permit. It is the criterion each country uses to decide whom it taxes and on what income. As a rule, the country where you are a tax resident taxes your worldwide income; the others tax only what originates there. Determining — and planning — your tax residence is therefore the first step of any international mobility.

The problem is that each country has its own rules for defining residence: number of days of presence, location of a permanent home, centre of vital interests, among others. Without planning, it is entirely possible to be considered resident in two countries at once — and that is where the complications begin.

Double taxation and treaties

When two countries claim the right to tax the same person or income, there is double taxation. To prevent this from penalising those with an international life, states enter into double taxation treaties, which define who may tax each type of income and how overlap is eliminated.

Knowing the treaty applicable to your specific case is essential: it often determines whether income is taxed in the source country, the residence country, or both with a tax credit. Ignoring it is one of the costliest mistakes in mobility.

Portugal: tax residence and the end of NHR

In Portugal, tax residence is defined by the Personal Income Tax Code (Código do IRS). For years, the country attracted new residents with the Non-Habitual Resident (NHR) regime. That regime was closed to new applicants and replaced by a new, more restricted incentive focused on scientific research and innovation (IFICI).

The lesson is clear: tax regimes change, and planning based on yesterday's rules may not serve today. We therefore always confirm the framework in force before any decision.

Plan before, not after

The right time to deal with tax residence is before moving. Once the move is done, many optimisation options are gone, and fixing things afterwards is always costlier and more limited. Prior planning lets you choose the timing of the move, organise your exit and entry, and align it all with the wealth structure.

Legal references

Tax residence in Portugal is defined by the Personal Income Tax Code (Código do IRS); residents' income is, as a rule, taxed on a worldwide basis.
The former Non-Habitual Resident (NHR) regime was closed to new applicants and replaced by the IFICI, created under Law no. 82/2023, of 29 December (2024 State Budget).
Double taxation is addressed by the double taxation treaties signed by Portugal, applicable case by case.
Rules and tax regimes change; we always confirm the framework in force in the official text before advising.

This article is general and informational and does not replace individual tax advice.