About Taxbordr: founder-led move-year planning
Taxbordr is a Portugal tax advisory firm founded by Telmo Ramos, Ordem dos Economistas Cédula nº 16379, formerly KPMG Luxembourg and EY Lisbon. Every move-year analysis, residency-timing memo, and first-year Modelo 3 is signed personally by Telmo. We work with cases from the UK, Germany, Canada, South Africa, the United States, and beyond, where the move-year sequence determines whether IFICI applies, which country gets which income, and how the first-year filing reconciles. The deliverable is a written Position Memo with a sequenced timeline your home-country advisor can use directly.
Pre-arrival: the months before you change address
The pre-arrival window is where you have the most options. First, model the residency-trigger date under CIRS art 16. Choose the year you want Portuguese residency to start. Realise pre-residency disposals where the home-country regime is more favourable. Second, identify departure-country exit triggers. United States citizens who renounce file Form 8854 and may face the section 877A exit tax on covered expatriates. UK leavers run the Statutory Residence Test and consider the FIG and TRF reforms in Finance Act 2025. Germans with a 1 percent or larger holding in a corporation face Wegzugsbesteuerung under § 6 AStG, which can be deferred but only with structured planning. South Africans cease tax residency through SARS RAV01, with the Section 9H deemed-disposal exit charge replacing the phased-out financial-emigration procedure since 1 March 2021. Canadians model the departure tax under section 128.1 ITA. Third, choose the regime path. NHR is closed: new applicants cannot start NHR after 1 January 2024. The transitional window under Lei 82/2023 art 236 closed 31 March 2025. IFICI under EBF art 58-A is the active-income successor with a 20 percent flat rate on qualifying Cat A and Cat B income for ten years. Fourth, set up Portuguese-side prerequisites: NIF before signing any lease, opening any bank account, or acquiring property; Portuguese bank account for residency-trigger evidence; lease or purchase document supporting habitual abode under CIRS art 16.
Arrival: the first 90 days
Once you arrive, the first 90 days carry several Portuguese-side mechanical steps. Register at AT for tax-residency purposes. Open or upgrade Segurança Social registration to obtain a NISS if employment or self-employment is part of the picture. If self-employed, register the relevant CAE code and decide between Recibos Verdes simplified regime and Unipessoal Lda. If employed by a foreign company without Portuguese payroll, set up direct Cat A reporting. If joining IFICI through a Portuguese employer, gather the contract and CAE evidence required by Portaria 352/2024/1. Register for SNS access through the Centro de Saúde nearest your residence. Note that SNS access depends on residency and Segurança Social registration, not on regime status.
Move-year filing: when residency starts mid-year
Lei 82/2023 introduced the partial-year residency framework. The arrival-year is split between a non-resident segment and a resident segment, each declared separately. The non-resident segment covers Portuguese-source income only, taxed under the non-resident rules. The resident segment covers worldwide income from the residency-start date, with treaty allocation applied through Anexo J. The IFICI election is made on Modelo 3 Anexo L for the resident segment, separate from the application filed with AT by 15 January of the year after residency starts. Anexo H captures family-allowance and tax-credit deductions. Pre-residency capital gains realised before the residency-start date are not in scope.
First-year Modelo 3 documentation pack
The data needed for the first Modelo 3 is broader than for a clean Portuguese-only return. From the home country: closing payroll statements, pension statements, brokerage account year-end statements, dividend and interest summaries, real-estate rental statements, prior-year tax return for treaty-credit reconciliation. From Portugal: Portuguese employer payroll if applicable, Portuguese bank account interest statements, Portuguese rental statements if applicable, Portuguese property-acquisition deed if applicable, IFICI application acceptance if filed. The pack supports both the Portuguese filing and the home-country filing, which usually needs treaty-credit data from the Portuguese return.
Common move-year mistakes
First, signing a Portuguese lease before NIF and tax-residency planning are settled, which can pull residency into the wrong calendar year. Second, realising disposals after the residency-start date when pre-residency disposal would have been cleaner. Third, missing the IFICI 15 January application deadline because the year-end is busy with logistics. Fourth, assuming NHR is still available, six months too late. Fifth, treating the home-country exit as automatic without filing the relevant exit forms (Form 8854, P85, RAV01, NR73 / NR74).
What this guide is not
This page is general guidance, not advice on your specific situation. The right move-year sequence depends on the calendar of disposals, the structure of compensation, the holding period of investment assets, and the timing of permanent-establishment risk in the home country.
Frequently Asked Questions
When does Portuguese tax residency start when moving in mid-year?
Under CIRS art 16, residency starts on the date the 183-day count is met or, alternatively, on the date a habitual abode is established. Lei 82/2023 introduced a partial-year residency framework that splits the year into a non-resident segment and a resident segment, each declared separately.
What is the order of Portuguese-side registrations for a new arrival?
NIF first, then Portuguese bank account, then lease or property acquisition, then AT residency registration, then NISS for Segurança Social if employment or self-employment is in scope. NIF is required for almost every other step.
Can I still apply for NHR in 2026?
No. NHR closed to new applicants on 1 January 2024 under Lei 82/2023. The Disposição transitória in Lei 82/2023 art 236 allowed late applications until 31 March 2025, with extensions under Despacho 24/2025-XXIV. Existing 10-year NHR registrations continue.
What is the IFICI application deadline for a 2025 arrival?
15 January 2026 for the application filed with AT, plus the IFICI election declared on Modelo 3 Anexo L for the 2025 income year, filed by 30 June 2026.
Do I need to file a US, UK, German, or Canadian exit return?
Often yes. US citizens who renounce file Form 8854. UK leavers may file P85 to claim split-year treatment under the Statutory Residence Test. Germans report Wegzugsbesteuerung under § 6 AStG where a 1 percent corporate stake or higher is involved. Canadians file departure-year T1 with section 128.1 deemed disposal disclosures.
When is my first Portuguese Modelo 3 due?
30 June of the year after residency starts. For a 2025 arrival, the deadline is 30 June 2026, with the filing window opening 1 April 2026.