An NHR settlement is the same subtraction as everyone else's (tax due minus retenção), but with a far simpler tax: 20% of net income, no brackets, no surcharges. The subtlety sits in three places: the retenção hits the gross (hence the refund), englobamento can beat the 20% at lower incomes, and deduções à coleta are disputed ground. The simulator handles all three.
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The base: net income, not gross
The NHR special rate hits "net income" (art. 72(10) of the CIRS, in the pre-2024 wording that the transitional regime keeps alive for existing NHR holders). For employment income, net means after the dedução específica: €4,462.15 in 2025 or, if higher, your Segurança Social contributions (11% of gross, which kicks in above roughly €40,565).
- 2
The rate: a flat 20%, no brackets
No brackets, no couple quotient, no solidarity surcharge: eligible income pays 20% of the net, per income holder, full stop. That is also why the mínimo de existência (existence minimum) and IRS Jovem play no part: the first only abates aggregated income, and anyone who ever held NHR status is excluded from the second (art. 12-B(9)).
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Why a refund appears
During the year, the employer withholds 20% of the monthly gross (art. 99(8), prior wording). At settlement, the final tax is 20% of the net. The difference (20% of the dedução específica) comes back to you: €892.43 up to ~€40,565 of gross and, above that, 2.2% of gross. If the employer applied the normal withholding tables instead of the 20%, it withheld considerably more and the refund grows by the same amount: the retenção is always provisional.
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The englobamento option
The 20% is a right, not an obligation: you may opt for englobamento (art. 72(13), prior wording) and pay by the general brackets, which start at 12.5% in 2025. It pays off at lower incomes: roughly below €31,000 gross the brackets beat the 20%, and with englobamento you regain the mínimo de existência and the deduções à coleta. The option is ticked in table 6-A of anexo L and drags in all income of that category (art. 22(5)). The simulator compares both routes.
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Deduções à coleta: the contested point
Health, education, rent, general family expenses: in the AT's practice, these credits only reduce the bracket-based tax. The 20% tax is untouched. Arbitration courts have ruled the other way (CAAD decisions 431/2022-T and 208/2024-T hold that the "coleta" includes special-rate tax), but there is no firm ruling on the personal credits and the AT has kept its reading. The simulator follows AT practice (which is what your assessment note will show) and applies the credits only in the englobamento scenario.
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The settlement: refund or a bill
The 2025 withholding is subtracted from the assessed tax. Withheld too much? The AT refunds it: by law up to 31 August 2026 (art. 102-B), in practice a few weeks after filing. Withheld too little (rare for NHR with 20% withholding), you pay the difference by the same date.
Frequently asked
Am I still NHR in 2025? Did the regime not end?
The regime closed to new sign-ups, but not for those already inside: if you registered, you keep the 10 consecutive years counted from the registration year (art. 16(9), prior wording). The transitional rules of Lei 82/2023 (art. 236) still admitted people who met the conditions on 31/12/2023 or became resident by 31/12/2024 with ties created in 2023 (employment contract, lease, visa…). Those registered by 31 March of the following year. For 2025 income, an active NHR uses the old rules in full.
My employer withheld by the normal tables, not at 20%. Did I lose the regime?
No. The retenção is a payment on account: it does not set the final tax. If you are an NHR in a high value-added activity, the settlement still applies the 20% to your net income, and everything over-withheld comes back as a refund. Under the normal tables, a €60,000 salary withholds around €14,000 while the final tax is about €10,700: the difference is yours. Going forward: give your employer proof of your NHR registration and evidence that your role is on the Portaria table, and they switch to the 20%.
My withholding was exactly 20%, so why do I get ~€892 back?
Because the retenção hits the gross while the final tax hits the net. The gap between the two is the dedução específica (€4,462.15 in 2025) and 20% of that is €892.43. Above ~€40,565 of gross, the dedução específica becomes your Segurança Social contributions (11%), and the refund becomes 2.2% of gross: €1,320 on a €60,000 salary, €2,200 on €100,000.
Do my health and education expenses really deduct nothing?
In the AT's practice, no: deduções à coleta only reduce the bracket-based tax, and someone taxed entirely at 20% has none. The reading is contested (arbitration courts have held that special-rate tax also counts: 431/2022-T, on the municipal benefit; 208/2024-T, on SIFIDE), but there is no firm ruling on health and education, and your assessment note will reflect the AT's practice. If you want to fight it, you can file an administrative claim or go to arbitration. The clean alternative: if englobamento works out better for you (lower incomes), the credits count in full.
When does englobamento pay off?
Roughly below €31,000 of annual gross: there the brackets' average rate falls under 20%, and you also regain the mínimo de existência (at low salaries) and the deduções à coleta. The simulator runs the exact numbers for your case. Note: the option drags in all income of the same category (art. 22(5)) and is ticked in table 6-A of anexo L.
How is this declared in the IRS declaration (Modelo 3)?
The salary goes in anexo A, like everyone's. Your NHR status and the high value-added activity go in anexo L (now titled "Non-habitual resident / IFICI"), with the activity code from the Portaria; in table 6-A you choose between the 20% taxation (field 01) and englobamento (field 02). Foreign income also goes in anexo J. Deadline: 1 April to 30 June 2026.
What about pensions and foreign income?
Outside this simulator, but in short: much of an NHR's foreign income is exempt under the exemption method (art. 81(4)-(5), prior wording) if the source country may tax it under the treaty; foreign pensions pay 10% for those who entered the regime from April 2020 (art. 72(12), prior wording). Cases with foreign income deserve an accountant: treaty details rule.
My 10 years are running out. What comes next?
The general regime, no safety net: brackets up to 48%, plus the solidarity surcharge above €80,000. There is no renewal, and the two obvious exits are shut: IFICI excludes anyone who ever benefited from NHR (art. 58-A(10) EBF), and so does IRS Jovem (art. 12-B(9)). The last year is worth planning ahead (timing of bonuses, mais-valias, PPR).
DISCLAIMER
An estimate for orientation, not tax advice. It simulates the 2025 IRS settlement of one NHR holder with employment income (category A) from a high value-added activity, mainland Portugal. It follows the AT's practice: deduções à coleta do not reduce the 20% tax (a reading contested in arbitration) and only enter the englobamento scenario. It does not cover category B, foreign income, pensions (10%), other aggregated income, two-earner households or the Madeira/Azores rates. The real number is the one on the assessment note. Confirm on the Portal das Finanças.