Compared
Beckham Law vs Portugal’s IFICI (the NHR successor): 24% for six years or 20% for ten?
Spain’s impatriate regime compared with Portugal’s IFICI, the scheme that replaced the NHR in 2024: rate, duration, who qualifies, foreign income, the application deadline and the fine print that decides which one fits your job and your assets.
Javier López Founder · holds the Beckham regime · not a lawyer
Portugal and Spain are the two countries people most often weigh against each other, and until 2024 Portugal usually won the tax argument on paper: the NHR offered ten years, a 20% rate on eligible professions and broad exemptions on foreign income. The NHR is closed to new arrivals. Its successor, the IFICI, keeps the rate and the duration but narrows who gets in. That changes the comparison.
Side by side
| Spain (art. 93 LIRPF) | Portugal (IFICI) | |
|---|---|---|
| Rate on employment income | Flat 24% up to €600,000, 47% above | Flat 20% on income from eligible activities |
| Duration | Year of the move plus five (up to six tax years) | Ten consecutive years |
| Who qualifies | Any employee with a Spanish contract, posted workers, remote employees of foreign employers, directors, ENISA entrepreneurs, qualified professionals for start-ups | People working in listed activities: research and higher education, certified start-ups, companies benefiting from certain investment or R&D incentives, listed highly qualified professions, some export-oriented companies |
| Self-employed | Excluded, except the ENISA and start-up routes | Eligible when the activity is on the list |
| Prior non-residence | Five tax years | Five years, and never having used the NHR |
| Foreign non-employment income | Outside Spanish tax | Generally exempt; income from blacklisted jurisdictions taxed at 35% |
| Application deadline | Modelo 149 within six months of Social Security registration | Registration by 15 January of the year after becoming resident |
| Wealth tax | On Spanish assets only | None; AIMI on Portuguese property above a threshold |
| Foreign-asset reporting | Not required during the regime | Portuguese rules apply |
Foreign rules summarised as we understand them in September 2026; confirm the Portuguese side with a local adviser. The treatment of foreign income is checked against the Portuguese Tax Authority’s IFICI FAQ.
Where Portugal wins
The rate and the duration. Twenty percent for ten years is a better deal than 24% for six, if you get in. A researcher, a university lecturer, someone hired by a certified start-up or a company with the right incentives, or a professional in one of the listed occupations, gets a regime that is both cheaper and longer.
Where Spain wins
Access. The Spanish regime does not ask what you do. A sales director, an accountant, a project manager, a remote employee of a foreign company, a posted engineer: all qualify with no activity test. Under IFICI, many of those people would not be eligible at all, and the comparison becomes 24% for six years against Portugal’s ordinary progressive tax, which reaches 48% plus a solidarity surcharge.
Spain also takes remote employees of foreign companies explicitly, through the telework route and the digital nomad permit, which is the profile that has grown most since 2023.
The fine print on both sides
- Spain taxes all employment income, including the part earned on days worked abroad, and applies no allowances. At moderate salaries, or with several dependants, the ordinary Spanish IRPF can be cheaper than the regime; our calculator says so when it happens.
- Both regimes leave you without a treaty residence certificate in practice, or with a weaker one, which affects withholding on dividends and pensions from your home country.
- Portugal’s list moves. Eligible activities and employers are defined by regulation and have been adjusted since 2024. Confirm eligibility before, not after, accepting a job.
- Spain’s deadline is unforgiving: six months from Social Security registration, counted from a date most people do not notice. Portugal’s 15 January cut-off is a fixed calendar date, easier to remember, equally fatal if missed.
- Wealth: Spain charges wealth tax on Spanish assets above the regional threshold, and the state large-fortunes tax above €3 million. Portugal has no wealth tax, only the AIMI on Portuguese property.
Which one for whom
- Employee in a non-listed role, or remote for a foreign employer: Spain. Portugal’s regime is not available to you.
- Researcher, academic, certified start-up hire, listed profession, planning ten years: Portugal, on the numbers.
- Significant foreign investment income: both work during the regime; Portugal for longer.
- Family with several children and a moderate salary: compare against both countries’ ordinary regimes, because neither special regime gives family allowances.
The decision is rarely about the rate alone. It is about whether you qualify at all, how long you intend to stay, and what income you have outside employment. Run the Spanish side with our calculator and diagnosis; have the Portuguese side confirmed by a local adviser against the current list.
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Frequently asked questions
Is the Portuguese NHR still available?
Not for new arrivals. The NHR closed to new applicants from 2024, with transitional cases. Its successor, the IFICI (sometimes called NHR 2.0), applies a 20% rate for ten years to income from a list of eligible activities and employers.
Which regime has the lower rate?
Portugal’s IFICI, at 20% against Spain’s 24%, and it lasts ten years against six. The catch is eligibility: IFICI covers listed activities (research, higher education, certified start-ups, companies with certain incentives, listed qualified professions). Spain covers any employee, posted worker, director or remote employee of a foreign company.
How do the two treat foreign income?
Similarly, with different mechanics. Spain taxes only Spanish-source income plus all employment income; foreign dividends, gains and rents are outside Spanish tax during the regime. IFICI generally exempts foreign-source income; the Portuguese Tax Authority confirms that income from blacklisted tax-haven jurisdictions is taxed at 35%.
Which deadline is stricter?
Spain’s: Modelo 149 within six months of Social Security registration, no extensions. Portugal’s IFICI requires registration by 15 January of the year after you become resident. Both are lost if missed.
Want to know where you stand?
Five minutes, no sign-up: verdict, deadline and what it is worth. Or ask to be matched with a registered professional for a fixed quote.
General information, not tax or legal advice. The regime has cumulative requirements and a 6-month deadline with no extensions; whether it fits you depends on your full situation. Foreign rules are summarised as we understand them in September 2026 and change often. Confirm the other country’s side with a local advisor before deciding.
More in this series
See all →Italy impatriati
On salary alone Italy’s 50% exemption often beats a flat 24%. Spain wins on foreign income, duration and having no qualification test.
Greece 50% exemption
Greece exempts half of your local salary for seven years. Spain covers foreign employers and leaves foreign income alone.
Netherlands 30% ruling
A tax-free slice inside the ordinary Dutch system, or a flat 24% outside it. The ruling is shrinking; the Spanish regime is not.