Category: Residency

Taxpayers who are NHR (Non-Habitual Residents) or IFICI (Incentive for Scientific Research and Innovation) eligible, benefit from a package of respective tax advantages, for a period of 10 consecutive calendar years (with the option of utilising the marginal rates, if lower), from the effective date of Portuguese tax residency.

Summary of Tax Consequences Differentiating between the Previous and New NHR (IFICI/NHR2.0) Regime

	Previous NHR Regime (Grandfathered – respective tax residents continue to benefit from old rules)	New NHR Regime (“NHR 2.0”), IFICI (Effective 1 January 2024)
Who does this apply to?	Those who became tax resident before 31 December 2023, or those, under the transitional rules, became tax resident before 31 December 2024.	Those who become tax resident on or after 1 January 2024 onwards and comply with the respective criteria – see link.
Employees or contractors of a Portuguese based entity	20% taxation for high value-added activities.	20% taxation for work for certain eligible activities.
Employees or contractors working for a foreign based company (exception for exempt salary income)	20% taxation for high value-added activities if the income is not taxed in the source state.	Not subject to tax if a high value-added activity or otherwise subject to progressive taxation up to 48% plus surtaxes.
HNWI deriving only passive related income (foreign)	Only certain foreign passive income may be exempt. Portfolio gains generally taxed at 28%. Blacklisted tax jurisdictions (35%).	Not subject to tax, with exception from blacklisted tax jurisdictions (35%).
HNWI deriving only passive related income (local/Portugal)	28% (unless marginal rates apply, if lower), or other exemptions.	28% (unless marginal rates apply, if lower), or other exemptions.
Pensioners	10% or exempt.	Progressive taxation up to 48% plus surtaxes.
R&D work performed in Portugal	20% taxation for high value-added activities. Other foreign passive income may be exempt.	20% taxation for work for certain eligible activities. Exempt on foreign income from several categories of income.

I am part of the previous NHR – does this affect me?

As the previous NHR regime will be grandfathered (including those who become tax resident before 31 December 2024), there is no impact for individuals already enjoying NHR status. The regime will continue to exist until the 10-year NHR period is reached, from when each respective individual registered for NHR.

Contact Us

Dixcart Portugal provide a host of services to international clients. Reach out for more information (advice.portugal@dixcart.com).

Note that the above must not be considered as tax advice and is for discussion purposes only.

Following the Government’s release of regulations in December 2024, Portugal has reintroduced a new Non-Habitual Residents Regime (NHR), known as “NHR 2.0” or IFICI (Incentive for Scientific Research and Innovation). The new regime is, effective from 1 January 2024 – a redesigned tax incentive scheme replacing the previous NHR.

The scheme, to summarise, is to allow those who choose Portugal as their base for establishing their business or exercising a respective professional activity in Portugal, to benefit from several tax advantages.

The key benefits, available for 10 calendar years from the time they become tax resident in Portugal, are summarised as follows:

• 20% flat tax rate on qualifying Portuguese income.
• Exclusion from tax for foreign-sourced business profits, employment, royalties, dividends, interest, rents, and capital gains.
• Only foreign pensions and income from blacklisted jurisdictions remain taxable.

Requirements for the New NHR:

Those intending to benefit from the new NHR can do so provided they comply with the following set of requirements:

1. Application Deadline: Applications must generally be submitted before 15 January of the following year after becoming tax resident in Portugal (Portugal’s tax years run in line with calendar years). A transitional period applies for those who became tax resident between 1 January and 31 December 2024, with a deadline of 15 March 2025.
2. Prior Non-Residency: Individuals must generally not have been tax resident in Portugal in the five years preceding their application.
3. Qualified Professions: To be eligible, individuals must be employed in at least one highly qualified profession, including:
   • Company Directors
   • Specialists in physical sciences, mathematics, engineering (excluding architects, urban planners, surveyors, and designers)
   • Industrial product or equipment designers
   • Doctors
   • University and higher education teachers
   • Specialists in information and communication technologies
4. Qualification Criteria: Highly qualified professionals typically require:

1. A minimum of a bachelor’s degree (equivalent to Level 6 on the European Qualifications Framework); and
2. At least three years of relevant professional experience.

5. Business Eligibility: to qualify for the Portuguese NHR under the business eligibility criteria, individuals must be employed by companies that meet specific requirements, namely:
   • Eligible businesses must operate within specific economic activity codes (CAE) as outlined in the Ministerial Order.
   • Companies must demonstrate that at least 50% of their turnover is derived from exports.
   • Belong to eligible sectors, including extractive industries, manufacturing, information and communication, R&D in physical and natural sciences, higher education, and human health activities.
6. Application Process:
   • Specific forms must be submitted to the relevant authorities (which may include the tax authorities) for eligibility verification. This is something Dixcart Portugal may assist with.
7. Application Documents: Required documents may include:
   • Copy of employment contract (or scientific grant)
   • Up-to-date company registration certificate
   • Proof of academic qualifications
   • Statement from the employer confirming compliance with the activity and eligibility requirements
8. Annual Confirmation:
   • The Portuguese tax authorities will confirm the NHR 2.0 status annually by 31 March.
   • Taxpayers must maintain records demonstrating that they carried out the qualifying activity and generated the corresponding income during the applicable years and provide this evidence upon request to benefit from the respective tax advantages.
9. Changes and Termination:
   • If there are changes to the original application details that affect the competent authority or the entity verifying the value-added activity, a new application must be filed.
   • In case of any changes to, or termination of, the qualifying activity, taxpayers are required to inform the relevant entities by 15 January of the following year.

What are the Tax Consequences for my Income Sources?

The tax rate and treatment will vary – please refer to our article on Tax Consequences of the Non-Habitual Residents Regime for more information.

Contact Us

Dixcart Portugal provide a host of services to international clients. Reach out for more information (advice.portugal@dixcart.com).

Note that the above must not be considered as tax advice and is for discussion purposes only.

What is the Malta Permanent Residence Programme (MPRP)?

The Malta Permanent Residence Programme (MPRP) was introduced in 2021, when it replaced the Malta Residence and Visa Programme (MRVP). The MPRP is designed to grant permanent residency to non-EU/EEA/Swiss nationals and their eligible family members. The programme aims to attract foreign investment while offering successful applicants the right to reside in Malta and access benefits such as visa-free travel within the Schengen Area.

As per Legal Notice 310 of 2024 published by the Maltese Government on 19 November 2024, the MPRP has undergone several key changes to the eligibility criteria and overall costs. MPRP. These amendments affect all MPRP applications from 1 January 2025.

What are the Key Changes?

The most significant changes are as follows:

• New Financial Eligibility Criteria

Prior to the changes taking effect in January 2025, applicants were required to possess a minimum of €500,000 in assets, including at least €150,000 in financial investments. Under new provisions, applicants will have two options:

1. showing that they have capital assets of a minimum €500,000, out of which a minimum of €150,000 must be financial assets; OR
2. show they have capital assets of a minimum €650,000, of which €75,000 must be in the form of financial assets.

• Age Limit for Dependant Children and New Fees for Dependants

Before the changes in the rules, a dependant child included in the application could be over 18 years old, unmarried, and primarily financially reliant on the main applicant. This applied to biological and adopted children of the main applicant or their spouse, provided they met the criteria set by the Residency Malta Agency. From 1 January 2025, the definition of a dependant child will change to include only those who are under 29 years old at the time of application. This new age limit does not apply to adult children certified by a recognised medical authority as having a disability.

A fee of €10,000 per dependant has been introduced, consisting of a combination of a €5,000 non-refundable administrative fee and a €5,000 financial contribution. There are no fees for dependants apply under the current version of the programme.

• Qualifying Property Costs

The minimum thresholds for qualifying owned or rented property are set to increase.

Post-amendments, starting 1 January 2025, the minimum property purchase value will increase to €375,000 (previously, the minimum price was €300,000 for properties in Gozo or the South of Malta and €350,000 for properties in other areas) and the minimum annual rent for qualifying rented property will increase to €14,000 (before this change, the minimum annual rent was €10,000 for properties in Gozo or the South of Malta and €12,000 for properties in other regions).

Under the new provisions, the location of the property will not impact the financial contributions due by the applicant.

• Main Applicant’s Financial Contribution

The contributions that applicants will have to pay have increased from €28,000 to €30,000 for applicants who choose a qualifying owned property, and from €58,000 to €60,000 for those who opt for a qualifying rented property. The contribution must be made within eight months of the issuance of the approval letter.

• Administrative Fee

The administration fee for applications submitted after 1 January 2025, will increase to €50,000 (from €40,000 under the previous regime). This fee is non-refundable, with €15,000 payable within one month of application submission and the remaining €35,000 due within two months of receiving the letter of approval in principle. For dependants, a total fee of €10,000 will apply (an increase from €7,500). Of this, €5,000 is a non-refundable administration fee, which must be paid within two months of the letter of approval in principle. The remaining €5,000 is payable within eight months of the same letter. If a dependant is added after the certificate of residence is issued, the non-refundable portion must be paid when the application is submitted.

There will be no changes to the investment route which involves making a donation of €2,000 to a local philanthropic, cultural, scientific, artistic, sport or animal welfare NGO registered with the Commissioner of Voluntary Organisations.

How Dixcart Can Assist?

The Dixcart office in Malta has extensive experience in guiding clients through the application process of the MPRP and the various residence programmes available in Malta.

For further information, please contact Jonathan Vassallo at the Dixcart office in Malta: advice.malta@dixcart.com. Alternatively, feel free to reach out to your usual Dixcart contact.

Introduction

For a long time, countries worldwide have had schemes such as the Portuguese NHR, the Italian Flat Rate Scheme, and the Cyprus Non-Domicile Regime.

With the rise of global mobility in the modern world, schemes like these are becoming more and more popular. They provide individuals with the opportunity to live in a beautiful country, full of culture, with the advantage of beneficial tax regimes.

Whether you are enjoying a remittance style taxation system, a list of exempt incomes, or even a lumpsum single annual charge, Cyprus is an appealing jurisdiction to consider for managing wealth.

In this article we explore the benefits of using a Cyprus Holding Company for individuals taking advantage of a Non-Dom regime.

Key Advantages

Cyprus has a fantastic corporate tax regime and as a result has become world renowned for being a favourable place to establish a holding company.  Some of the key features and benefits of a Cyprus Holding Company can be found here (link to article) below.

Taxation of income

Cyprus has one of the lowest rates of corporation tax in the EU at 12.5%. This rate however can be considerably lower if you are eligible to apply for the Notional Interest Deduction (NID) which can reduce corporate tax to a rate as low as 2.5%.

In addition to the low rate of corporation tax, the following sources of income are exempt from corporation tax (which is not limited to holding companies):

• Dividend Income
• Interest income, excluding income arising in the ordinary course of business, which is taxed under corporation tax
• Foreign Exchange (FX) gains, excluding FX gains arising from trading in foreign currencies and related derivatives
• Capital Gains, excluding gains from the sale of immoveable property in Cyprus or shares in companies owning such property

It should also be noted that a Cyprus Holding Company is required to have sufficient economic substance in Cyprus to be considered a tax resident company.

Other benefits

In addition to the above-mentioned rates and exemptions, there is also 0% withholding tax (WHT) in Cyprus and over 60 Double Taxation Treaties which allow for transfers of Dividends, Interest and Royalties at reduced taxation rates in the countries received.

The key point regarding WHT is that Cyprus is a member of the EU and as a result has access to the EU Parent-Subsidiary Directive, provided the company is the Beneficial Owner of the income. This Directive aims to eliminate WHT and double taxation from transactions within the same group within the EU.

Cyprus being a member of the EU also means that it is fully OECD compliant and is whitelisted internationally. This makes processes like opening a bank account or purchasing investments, such as property, much easier than using a non-whitelisted country.

How Does This Help You?

While Non-Domicile Regimes vary, they often fit one of three categories: a remittance basis, flat rate taxation, or exempt incomes.

Using a Cyprus Holding Company can benefit individuals being taxed under each of these three categories and the advantages listed earlier in the article lend themselves perfectly to be adaptable to suit your needs. Below we outline how they can be used to help you:

• The use of a Holding Company is, by design, a method of collating your earnings and investments in one place. If this place is outside of your personal tax resident country, then this will not impact your personal tax liability if you are taxed under the remittance basis. You may also end up with a lower rate of WHT across your investments by using Cyprus. You can let the wealth build up in your Cyprus Holding Company and only remit exactly what you chose to remit.
• If you are living in a jurisdiction in which various forms of income are exempt, such as dividends in Portugal, having your wealth accumulate in one place and then being able to remit a portion of the accumulated wealth to yourself using an exempt method, could result in considerable savings. It would also enable you to use what is left in the Company to generate more income through further investment. If your investments are EU based, this may eliminate WHT from the structure as a whole.
• If you are paying a flat rate of tax, like for example in Switzerland or Italy, you may think that your savings would be limited because you pay the flat rate either way. However, the use of a Cyprus Holding Company as a method of investment management can impact other taxes such as WHT savings and inheritance tax.

How Can Dixcart Help?

With over 50 years of experience in the sector, we have a wealth of knowledge in assisting families, and our teams offer in-depth expert knowledge on the local regulatory framework, along with the backing of our international group of offices, to help us find the perfect solution for you.

At Dixcart, we know that every individual’s needs are different, and we treat them as such. We work very closely with our clients and have an in-depth understanding of their needs. This means we can offer the most bespoke services possible, propose the most appropriate structures, and support your specific requirements every step of the way.

We offer services ranging from company incorporation, management and accounting services, and company secretarial services, all the way to providing a serviced office for your Cypriot company.

If you are interested in discussing your options and how using Cyprus to manage your wealth could help you, please contact us. We will be happy to answer any questions you have and assist in any way we can: advice.cyprus@dixcart.com.

The Portuguese Golden Visa remains golden for a reason – despite its various changes since its introduction in 2012. Thousands of families have benefited from the programme, identifying the second residency option as a high-net worth essential.

The residency-by-investment programme allows non-EU/EEA citizens to obtain a Portuguese residence permit in exchange for an investment in Portugal – namely:

• 💰Fund investment: Investing a minimum of €500,000 in a Portuguese non-real estate collective investment fund (see here for more information), OR

• 🏢Commercial Company: one of the following two options are available:
  • Newly incorporated: a capital transfer of at least €500,000, with headquarters in Portugal, combined with the creation of five permanent jobs,
  • Existing company; capital transfer of at least €500,000, with headquarters in Portugal, combined with the creation of five permanent jobs, or maintenance of 10 jobs, OR
• 🖥️Job Creation: creation of 10 jobs, OR
• 📊Research Activities: a capital transfer of €500,000 to a private or public scientific research institution (or €400,000 in a low-density areas), OR
• 🎨Artistic Productions: a capital transfer of €250,000 for investment in artistic productions reflecting national cultural heritage (or €200,000 in a low-density area).

Benefits of the Portuguese Golden Visa Programme

• EU citizenship
• Family reunification
• Visa-free travel in Schengen area
• Tax benefits
• Lower investment and more flexibility than other EU residency programs
• Minimum requirement of 7 days average stay in Portugal per year
• Individuals who choose to become tax resident in Portugal can benefit from the Non-Habitual Residents Programme (it is possible for non-EU individuals to apply to the two schemes simultaneously)

Why Choose Portugal?

Portugal is a popular destination for investors due to its high quality of life, stable economy, and favourable tax regime. The country offers a beautiful climate, excellent healthcare, and a strong educational system.

Need More Information?

Reach out to Dixcart Portugal who will introduce you to independent legal advisors and consultants who will assist you with the process. With decades of experience in the private client sector, and we look forward to helping you. Reach out to advice.portugal@dixcart.com.

July 2025: The Portuguese Parliament has begun discussing significant changes to the country’s nationality and immigration laws, including extending the required residence period for citizenship and altering how that period is calculated. These proposed amendments, which also cover stricter requirements for family reunification, are still in early stages and may be subject to revisions.

Cyprus Residency Options for Non-EU Citizens

Dixcart has over 50 years of experience in assisting and advising individuals with their residency applications. It is important to note that each option has its varying advantages and requirements, so it is critical for us to understand which option will be best suited for you.

As a non-EU national, there are four main options for obtaining residency, as outlined below:

1. Permanent Residence through Investment
2. Establishment of a Foreign Interest Company
3. Permanent Residency Programme (PRP) – ‘Slow Track’
4. Temporary / Retirement / Self-Sufficiency Residence Permit

To help you understand the options, we have broken down the detail of each option below.

Permanent Residence through Investment

If you wish to use the residency by investment route, then you will be required to make an investment of €300,000 + VAT. There are several investment options to consider, the most common of which is residential real estate.

In order to be eligible to for this option you must meet the following criteria:

• Be over 18 years old
• Have no criminal record or prosecution, restrictions or bans on entry to the EU and the UK
• Not be under sanctions
• Maintain an income of €50,000 per year for the main applicant (plus €15,000 for a spouse and €10,000 for any additional children)
• Own or rent accommodation (applicable for those not investing in residential real estate)
• Provide a medical report
• Obtain medical insurance

It is important to note that this immigration permit does not allow the applicant and their spouse the right to work. As a result, they are not able to undertake any form of employment in Cyprus. However, they are permitted to own Cyprus companies, act as directors, and receive dividends.

The applicant and their spouse must certify that they do not intend to be employed in the Republic of Cyprus with the exception of being Directors of a Cyprus company.

If you are successful in your application, then permanent residency is issued for life. After 5 years of living in the Republic of Cyprus, the holder of a permanent residency can apply for a passport (subject to conditions) and become a citizen of the EU.

Establishment of a Foreign Interest Company

A Foreign Interest Company is an international company, which, subject to meeting specific criteria, can employ non-EU national employees in Cyprus. This programme enables key employees and their families to gain residence, and work permits under favourable terms.

It also allows the owners of the company to apply for a work permit and residency through the company. This means that they will have the right to live and work in Cyprus and can bring their employees with them. Their family members are also allowed to apply to live in Cyprus.

All parties also benefit from both the individual tax rate savings and the corporate tax savings available in Cyprus, including the non-Domicile status.

The Main Requirements Enabling an International Company to qualify as a Foreign Interest Company:

• The third country shareholder(s) must own more than 50% of the total share capital of the company.
• There must be a minimum Investment of €200,000 into the Cyprus Company by the third country shareholder(s). This investment can be used later to fund future expenses incurred by the company when it is established in Cyprus.

After 7 years of residency in Cyprus, individuals can apply for Cypriot citizenship (subject to conditions). Highly skilled foreign workers can now obtain Cypriot citizenship if they have resided in Cyprus for a shorter timeframe of 4 – 5 years (depending on Greek language knowledge).

Permanent Residency Programme (PRP) – ‘Slow Track’

The Cyprus Permanent Residency ‘Slow Track’ – also known as ‘Category F’ – programme is available to applicants who possess, and have fully and freely at their disposal, a secured annual income, high enough to provide a good standard of living in Cyprus, without having to engage in any business, trade, or profession. This is essential as this option gives you the right to live in Cyprus but not to work.

Whilst applicants are allowed to reside in Cyprus from the date of the official submission of the application, they should allow 12 to 18 months to obtain the Permit.

The Main Qualification Requirements are as follows:

• Annual income, that is sourced from outside Cyprus, of a minimum of €24,000, which increases by 20% for a spouse and by 15% for each dependant child
• A title deed or rental agreement for a residential property in Cyprus that is for the sole use of the applicant and his/her family
• A certificate of ‘no criminal record’ and of not being under investigation for criminal offences, that is attested by the relevant authorities of the applicant’s country of current residence
• Private Medical Insurance
• Whilst no minimum investment amount is specified, the higher the financial commitment, the more likely it is to be considered favourably. Typically, a property purchased for €150,000 will fulfil this requirement.

Temporary/ Retirement/ Self-sufficiency Residence Permit

The Cyprus Temporary Residence Permit is an annually renewable self-sufficiency visa that allows an individual and their qualifying dependants, to live in Cyprus as a visitor, without employment rights.

The Main qualification requirements are as follows:

• Annual income, that is sourced from outside Cyprus, of a minimum of €24,000, which increases by 20% for a spouse and by 15% for each dependant child
• A title deed or rental agreement for a residential property in Cyprus that is for the sole use of the applicant and his/her family
• A certificate of ‘no criminal record’ and of not being under investigation for criminal offences, that is attested by the relevant authorities of the applicant’s country of current residence
• Private Medical Insurance
• An original medical examination certificate to confirm that the applicant does not have certain medical conditions

N.B. It is essential that a holder of this temporary residence permit should not stay out of the country for more than three months at a time, because this could result in the permit being cancelled.

How Can We Help?

Dixcart (Cyprus) Management Limited is part of an independent group, established over 50 years ago. We have offices in various jurisdictions and can therefore offer you the most optimal solution in several jurisdictions, depending on your needs.

Get in Touch

If you require further information regarding residency in Cyprus for Non-EU Nationals, contact advice.cyprus@dixcart.com.

Relocating to a new country is a life-changing decision that cannot be taken lightly. Immigration status, residence permit, job availability, healthcare and education are just a few of the many elements individuals and their families need to assess before taking such an important step in their lives.

Malta is a strong option to consider for several reasons. Two of the main reasons to consider Malta is their economy, which has been constantly growing year after year and needs to increase its pool of workers. This trend is set to continue, with EU growth forecasts constantly placing Malta in the first position among EU countries. In addition to this, the Mediterranean climate and the island’s lifestyle are attractive for many foreigners. 

Definitions, Visa and Legal Basis to Stay in Malta

Third-Country Nationals (TCNs) are individuals who are not citizens of the European Union (EU), European Economic Area (EAA) or Swiss Nationals. To enter Malta, a Schengen visa is required. The Schengen visa would allow a TCN to stay in the Schengen area for a maximum of 90 days over a period of 180 days. Once this visa has expired, a TCN can remain in Malta only with a valid legal basis: this can be related to employment, self-sufficiency, family reunion, study, health or refugee status.

Planning to Work in Malta?

The Schengen visa does not allow its holder to work in Malta. To be able to reside and work in Malta, TCNs need to obtain a single permit, a document that combines residence and work permit. The single permit is valid for 1 year and indicates both the employer and the position/job title of the TCN. Should any of these details change a new single permit needs to be issued.

Highly skilled individuals can also benefit from the Key Employment Initiative (KEI), or the Specialist Employee Initiative (SEI), which provides a fast-track work permit for highly specialised TCNs who are employed in Malta.

Thinking of Self-Employment?

The single permit does not allow self-employment. TCNs who wish to set up a business in Malta, will require an employment license issued by Jobsplus, the Maltese Job Agency, which will grant it if one or more of the following conditions are met:

a) the TCN makes a minimum capital investment of €500,000;

b) the TCN is a highly skilled innovator who commit to recruit at least 3 people (EU, EEA or Swiss nationals) within 18 months;

c) the TCN has a project approved by Malta Enterprise, the Maltese Government FDI Agency. The TCN will be able to apply for a residency permit once the employment license is granted.

Are you able to Sustain your Residence in Malta Without Employment?

TCNs can apply for a residence permit via the following routes: Global Residence Programme, the Malta Permanent Residence Programme, and the Malta Retirement Programme. These are the only routes through which a TCN can obtain a residence permit based on self-sufficiency. For more information on these residency routes, we invite our readers to visit this page on our website.

Alternative Options for Startups and Digital Nomads

There are two additional routes for TCNs to work and obtain residency in Malta.

The Malta Startup Residence Programme targets founders and co-founders of innovative start-ups. Such individuals can relocate and live in Malta and can apply for a 3-year residency permit, together with their immediate family. It is possible to include Key Employees for the startup under this route.

TCNs can also apply for the Nomad Residency Permit, which is designed for individuals who wish to maintain their current job in another country, but legally reside in Malta and work remotely.

Individual Cases: Study and Health

TCNs may apply for a residence permit for the purpose of study. It is to be noted that, in this case, they are not allowed to work, unless they obtain an employment license by Jobsplus, which would allow them to work for up to 20 hours per week.

A residence permit can be granted to a TCN who intends to seek medical treatment in Malta. In this case, particular documentation needs to be submitted to Identità, the Maltese agency responsible for passports, visa, identity documents, work & residence documents.

Additional Information and Assistance

Our staff at the Dixcart Malta Office can assist in providing advice as to which route would be most appropriate for each individual or family.

We can also assist with visits to Malta applications, and provide a comprehensive range of individual and professional commercial services once relocation has taken place.

For further information about moving to Malta please contact: advice.malta@dixcart.com.

Dixcart Management Malta Limited Licence Number: AKM-DIXC-25.