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Navigating the labyrinth of cross-border taxation: Portugal’s NHR regime and tax residency
16/04/2026
If you are a Non-Habitual Resident (NHR) or an advisor in the Iberian space, a recent article by Samuel Fernandes de Almeida and Ana Rita Carvalho in ITR Local Insights published today highlights a brewing legal storm.
The Portuguese Tax Authorities (PTA) recently issued Binding Ruling No.29,111 and reaffirm that NHRs qualify as full tax residents, subject to worldwide taxation and, consequently, entitled to DTT protection.
In cross-border taxation, "paper residency" is no longer a sufficient shield. For NHRs with Spanish interests, documenting the substantiated link to Portugal (housing, family, economic activity) is now a mandatory risk-management strategy.
