Portugal NHR for US citizens: How the NHR 2.0 Program works in 2026
Portugal's NHR (Non-Habitual Resident) program attracted tens of thousands of US citizens to Lisbon, Porto, and the Algarve with flat tax rates and broad foreign income exemptions. The original Portugal NHR program officially closed to new applicants on 1 January 2024 and was replaced by IFICI – widely called Portugal NHR 2.0 – which targets a narrower group of qualifying professionals in technology, research, and innovation roles.
This guide explains what changed, who qualifies in 2025 and 2026, how the Portugal NHR tax regime interacts with your US filing obligations, and how to apply.
One point applies to every section: the US taxes its citizens on worldwide income regardless of where they live and regardless of NHR or IFICI status. NHR reduces your Portuguese tax bill; it does not reduce your IRS filing obligation.
TFX has prepared US expat tax returns for Americans in Portugal since 2004. Read our US tax preparation in Portugal guide or explore our full overview of moving to Portugal from the US for background on the full relocation picture.
What is Portugal NHR? A quick answer for US citizens
Portugal NHR (Non-Habitual Resident) was a special tax regime offering a flat 20% tax rate on Portuguese-source income and 10-year exemptions on most foreign-source income – replaced by NHR 2.0 (IFICI) on 1 January 2024.
The Portugal NHR explained in brief: the original regime, which ran from 2009 through 2023, allowed qualifying individuals who had not been Portuguese tax residents in the prior 5 years to pay a 20% flat rate on qualifying Portuguese employment income and exempt most foreign-source income from Portuguese tax, for up to 10 consecutive years. On 1 January 2024, Portugal replaced it with IFICI (Incentivo Fiscal à Investigação Científica e Inovação), rebranded by most practitioners as NHR 2.0. The core mechanics are similar; the eligibility is far narrower.
As a US citizen, the IRS requires you to file a federal tax return on worldwide income regardless of your NHR or IFICI status. NHR reduces your Portuguese liability; it does not change what you owe the IRS.
Quick answer: key figures
- 20% flat rate on qualifying Portuguese employment income (NHR 1.0)
- 20% flat rate on qualifying employment and self-employment income (NHR 2.0 / IFICI)
- 10-year benefit window from the year Portuguese tax residency begins
You can review our comparison of the foreign tax credit vs. foreign earned income exclusion to understand how these two strategies interact with NHR before reading further.
NHR 1.0 vs NHR 2.0 (IFICI): Key differences explained
NHR 2.0, officially called IFICI (Incentivo Fiscal à Investigação e Inovação), launched 1 January 2024 and narrows eligibility to specific high-value and innovation-focused professions, replacing the broad Portugal NHR scheme that previously attracted retirees, passive-income earners, and a wide range of high-added-value professionals.
The original NHR closed to new applicants on 31 December 2023. Existing NHR 1.0 holders retain their benefits for the remainder of their individual 10-year window. Individuals who became Portuguese tax residents in 2023 and applied for NHR 1.0 status under transitional rules by 31 March 2024 also retain NHR 1.0 benefits through their full period.
The following table compares both regimes across 5 key dimensions. NHR 2.0 (IFICI) retains the 20% flat rate but removes the pension benefit and requires annual proof of a qualifying professional activity – two changes that fundamentally narrow who benefits.
| Feature | NHR 1.0 (closed) | NHR 2.0 / IFICI (active) |
|---|---|---|
| Program name | Non-Habitual Resident (NHR) | IFICI – Tax Incentive for Scientific Research and Innovation |
| Effective dates | 2009 – 31 December 2023 | 1 January 2024 – present |
| Flat income tax rate | 20% on qualifying Portuguese-source income | 20% on qualifying Portuguese employment and self-employment income |
| Qualifying professions requirement | Broad "high added value" list; retirees eligible | Specific innovation, technology, research, and startup-sector roles; retirees generally excluded |
| Foreign income exemption | Broad exemption on dividends, interest, royalties, capital gains, and rental; 10% flat rate on foreign pensions | Exemption on qualifying foreign dividends, interest, and capital gains; no pension benefit |
For a practical walkthrough of how to claim Form 1116, read our guide to claiming the foreign tax credit – it is central to how US citizens in Portugal avoid double taxation. You can also review the Portal das Finanças, Portugal's official tax authority portal, for the current IFICI registration process.
Is NHR still available in Portugal in 2025 and 2026?
NHR 1.0 closed to new applicants on 31 December 2023, but NHR 2.0 (IFICI) is fully available in 2025 and 2026 for qualifying individuals who have not been Portuguese tax residents in the prior 5 years.
Portugal NHR 2.0 is the active regime in 2026. IFICI accepts applications from qualifying individuals who establish Portuguese tax residency in 2025 or 2026 and meet the professional activity requirements. Individuals who became tax residents in 2023 and applied under the transitional rules by 31 March 2024 retain NHR 1.0 benefits for the remainder of their 10-year window.
If you are a US citizen already in Portugal on a visa without NHR status, your US tax obligations do not change. Read our guide on IRS Form 8840 and the closer connection exception to understand how foreign residency and US tax filing interact before assuming NHR status resolves anything.
NHR 2.0 eligibility requirements for US citizens
US citizens must meet all Portuguese IFICI eligibility criteria while simultaneously maintaining their US tax filing obligations – there is no opt-out from US taxation.
The following 5 conditions must all be met to qualify for IFICI (Portugal NHR 2.0) status:
- You have not been a Portuguese tax resident in the 5 years prior to your application year.
- You are employed or self-employed in a qualifying high-value activity recognized under IFICI rules.
- You obtain a Portuguese NIF (Número de Identificação Fiscal), the Portuguese tax identification number required for all tax interactions with Portuguese authorities.
- You register as a tax resident in Portugal by spending more than 183 days in Portugal during the relevant calendar year, or by establishing a habitual residence there.
- You submit your IFICI application through the Portal das Finanças by 15 January of the year following your first year of Portuguese tax residency.
How to qualify for NHR in Portugal under IFICI also requires your employer (for employed individuals) to confirm annually through the Portal das Finanças that your role satisfies the regime's criteria – an ongoing compliance requirement that did not exist under NHR 1.0.
One frequently overlooked distinction: obtaining a Portuguese NIF does not establish tax residency. Many US citizens obtain a NIF before relocating for property purchases or banking purposes. See our guide to individual tax identification numbers for context on how identification numbers differ from residency status across jurisdictions.
Qualifying high-value activities under NHR 2.0
Unlike NHR 1.0, which covered a broad list of professions, NHR 2.0 focuses on innovation, technology, and research roles – making profession verification a critical first step for US citizens considering the move.
The IFICI regime organizes eligibility into 7 qualifying routes, each tied to a specific type of professional activity. The following 5 categories cover the most common routes for US citizens:
- Technology and IT professionals – software engineers, data scientists, and cybersecurity specialists may qualify only if both the role and employer fit an Article 58-A route. For example, a highly qualified ICT role may qualify through an eligible activity and export-revenue route, while AICEP or IAPMEI recognition applies to separate investment or economic-relevance routes.
- Scientific research roles – researchers working at Portuguese universities, higher education institutions, or recognized national innovation centers.
- Highly qualified employees of eligible investment project entities – professionals at companies recognized by AICEP (Agência para o Investimento e Comércio Externo de Portugal) under approved investment projects.
- Certified startup ecosystem roles – employees of companies certified under Portugal's official Startup Portugal program.
- Teaching in higher education – faculty roles at Portuguese universities and accredited academic institutions.
The NHR Portugal list of professions under IFICI is published by the Portuguese government and periodically updated through the Portal das Finanças and relevant agencies. US citizens with income from self-employment or foreign clients should understand how self-employment taxes when working outside the US interact with IFICI before relocating.
Not sure if you qualify for Portugal NHR 2.0?
Many US citizens discover after relocating that their profession does not qualify for IFICI, leaving them exposed to Portugal's standard progressive income tax rates – which reach 48% at higher income levels – on top of their unchanged US filing obligations.
Before you move to Portugal, verify your NHR 2.0 eligibility and US tax impact with a TFX expat tax specialist. One consultation can prevent years of costly mistakes.
Schedule a free call today to get started.
Portugal NHR tax benefits: What US citizens actually keep
Under NHR 2.0, qualifying US citizens pay a flat 20% Portuguese income tax on employment and self-employment income from qualifying activities – but still owe US taxes on worldwide income, which can significantly reduce the net benefit.
The Portugal NHR 2.0 tax benefits that survive dual-filing obligations are still meaningful for high earners in qualifying roles. The following 4 benefits apply to IFICI holders:
- For tax year 2025, Portugal’s mainland progressive IRS rates run from 12.50% to 48%, before any additional solidarity surcharge.
- Potential exemption on certain foreign-source income – dividends, interest, and royalties from non-blacklisted jurisdictions may be exempt from Portuguese tax; income from blacklisted jurisdictions is taxed at a punitive 35%.
- 10-year benefit window from the year of first Portuguese tax residency, provided the qualifying activity conditions are met each year.
- No Portuguese wealth tax – Portugal does not impose a general wealth tax on individuals.
The Portugal NHR tax regime details one key caveat for US citizens: the 20% Portuguese tax paid on qualifying income is generally creditable against US tax liability through Form 1116. That is how most US citizens in Portugal avoid double taxation. The IRS's Publication 54 (Tax Guide for US Citizens and Resident Aliens Abroad) is the authoritative reference for foreign income and credit treatment.
Understand the foreign earned income exclusion before deciding which strategy to use – for most NHR holders, the foreign tax credit produces a lower combined tax bill.
How US citizens use the foreign tax credit with Portugal NHR
The foreign tax credit on Form 1116 is typically more valuable than the foreign earned income exclusion for NHR holders because Portuguese taxes paid can offset US tax dollar-for-dollar.
Based on our client scenario at TFX: A US software engineer living in Lisbon under NHR 2.0 earns €80,000 in qualifying employment income. Portugal levies a flat 20% tax of €16,000. When filing the US Form 1040, the engineer claims a foreign tax credit on Form 1116 for the €16,000 paid to Portugal (converted to USD). The US federal tax liability on that income at a 22–24% marginal rate would be approximately $17,600–$19,200. The Form 1116 credit eliminates most or all of the US liability on that income, leaving little or nothing owed to the IRS.
This is how Form 1116 foreign tax credit works in the Portugal NHR context: you are not avoiding tax; you are preventing the same income from being taxed twice. A small residual US liability may remain if your US marginal rate exceeds Portugal's 20% flat rate on the same income.
Read our guide to IRS Form 2555 and the foreign earned income exclusion to understand when the exclusion approach is preferable to the credit approach.
Foreign earned income exclusion vs. foreign tax credit: Which is better for NHR holders?
Most US citizens under Portugal NHR 2.0 benefit more from the foreign tax credit (Form 1116) than the foreign earned income exclusion (Form 2555) because the 20% Portuguese flat rate generates creditable taxes that offset US liability more efficiently than the 2025 FEIE exclusion cap of $130,000.
The IRS Form 2555 Portugal strategy works like this: FEIE excludes up to $130,000 of foreign earned income (2025 tax year, filed in 2026) from US taxable income, which eliminates US tax on that income. The problem: it also wastes the 20% Portuguese tax you already paid, since there is no remaining US liability to credit it against. FTC (Form 1116) credits the Portuguese tax dollar-for-dollar against the US tax otherwise owed on the same income, typically producing a lower combined tax bill for NHR holders.
You cannot use both FEIE and FTC on the same income. Choosing the wrong strategy can cost thousands annually, particularly for US citizens with income above $130,000. Our foreign earned income exclusion denied case study illustrates what goes wrong when the wrong election is made.
FBAR and FATCA reporting for US citizens with Portuguese bank accounts
US citizens living in Portugal under NHR must file an FBAR (FinCEN Form 114) if their Portuguese bank accounts exceed $10,000 in aggregate at any point during the year, and FATCA Form 8938 if foreign assets exceed $200,000 on the last day of the tax year (single filer abroad) – and NHR status changes none of this.
The following 4 reporting obligations apply to every US citizen in Portugal, regardless of IFICI or NHR status:
- FBAR (FinCEN Form 114) – required when the aggregate value of all foreign financial accounts exceeds $10,000 at any point during the calendar year. Filed separately through FinCEN's BSA E-Filing System, with a deadline of April 15 and an automatic extension to October 15.
- FATCA Form 8938 – required when specified foreign financial assets exceed $200,000 on the last day of the tax year, or $300,000 at any point during the year (single filer abroad). This form is attached to your Form 1040.
- CRS / FATCA bank reporting – Portuguese financial institutions report US account holders to the IRS under the Common Reporting Standard and the US-Portugal FATCA intergovernmental agreement. The IRS likely already has information on your Portuguese accounts before you file.
- FBAR penalty exposure – for penalties assessed on or after 17 January 2025, the adjusted maximum civil penalty for a non-willful FBAR violation is $16,536. Willful violations can carry much higher penalties.
Read our detailed FBAR guide (FinCEN Form 114) for the full FBAR compliance picture. For FATCA requirements, see the FATCA reporting requirements overview and our FATCA and CRS reporting guide. The IRS also publishes authoritative FATCA guidance for US persons abroad.
US-Portugal tax treaty: What it covers and what it does not
The US-Portugal tax treaty helps prevent double taxation on certain income types, including pensions, dividends, and interest – but the saving clause means US citizens cannot use the treaty to escape US tax on most income, even while living in Portugal under NHR.
The saving clause (Article 1 of the US-Portugal convention) preserves the US right to tax its citizens as if the treaty did not exist. In practice, US citizens in Portugal cannot invoke most treaty provisions to reduce their US federal income tax liability. They must instead rely on the foreign tax credit or FEIE. The treaty does, however, define how taxing rights are allocated between the two countries, which affects how the foreign tax credit Portugal calculation works – particularly for pension and investment income.
One exception benefits US citizens with US-source dividend income: Article 10 generally caps source-country tax on dividends at 15% when dividends are paid by a company in one treaty country to a beneficial owner resident in the other. For US citizens resident in Portugal, the treaty’s saving clause means the United States may still tax its citizens as if the treaty had not come into effect, so the treaty should be framed as a withholding, sourcing, and credit rule – not a way to escape US tax. For US citizens who hold US dividend-paying investments while living in Portugal, this reduced rate directly affects the Form 1116 basket calculation.
See our guide on Social Security benefits for Americans living abroad – the treaty's provisions on pension and Social Security income affect the dual-taxation analysis significantly. The IRS publishes the official Portugal tax treaty documents, including the convention text and technical explanation.
Self-employment tax for US citizens under Portugal NHR
US citizens who are self-employed in Portugal under NHR 2.0 may qualify to be exempt from the US self-employment tax of 15.3% on net self-employment income up to $176,100 (2025) if they are covered by Portugal's social security system under the US-Portugal totalization agreement.
The US-Portugal totalization agreement, in force since 1 August 1989, covers self-employed individuals. Under the agreement's residence rule, self-employed individuals who reside in Portugal contribute to Portuguese social security – not US Social Security – and are generally exempt from the 15.3% US self-employment tax on that income. To establish the exemption, you must obtain a Certificate of Coverage (Certificado de Cobertura) from Portuguese social security authorities confirming you are covered under the Portuguese system. Without that certificate, the IRS's default position is that US self-employment tax applies.
Do not rely on Form 1116 to offset US self-employment tax with Portuguese social security contributions. If the US-Portugal totalization agreement assigns coverage to Portugal, document the exemption with a Portuguese certificate of coverage; if it does not, calculate the US self-employment tax separately from the foreign tax credit. See our update on the $176,100 social security taxable wage base for 2025 for the current threshold.
Passive income under Portugal NHR: Dividends, capital gains, and rental income
Under NHR 2.0, foreign-source dividends and interest may be exempt from Portuguese tax if sourced from non-blacklisted countries, but US citizens must still report and pay US tax on all passive income worldwide – using separate Form 1116 foreign tax credit baskets.
Passive income taxation Portugal expats face differs by income type and source. The following 3 income categories each carry distinct Portuguese and US treatment under IFICI:
- Dividends – Foreign-source dividends from non-blacklisted jurisdictions are potentially exempt from Portuguese tax under IFICI. Income from blacklisted jurisdictions is taxed at 35%. Taxable in the US as ordinary or qualified income; foreign tax credit available for any Portuguese tax paid. For the US treatment of non-resident capital transactions, see our capital gains tax guide for non-US residents – it covers key parallel issues.
- Capital gains – Under standard Portuguese rules, capital gains are taxed at 28% flat for tax residents, including IFICI holders. Taxable in the US as capital gains; FTC is available for Portuguese capital gains tax paid.
- Rental income from Portuguese property – Taxable in Portugal and must also be reported on the US return. For 2025, residential rental income is generally taxed at 25% in Portugal, with possible reductions for longer qualifying leases; other rental income may follow different Article 72 rules.
How to apply for NHR 2.0 (IFICI) in Portugal: Step-by-step
The IFICI application deadline of 15 January is strict – missing it means waiting until the next tax year and losing one year of the 10-year benefit window.
The following 6 steps outline how to apply for NHR in Portugal under the IFICI regime:
- Obtain your Portuguese NIF from a local Finanças office or through a Portuguese consulate. This is your Portuguese tax identification number and is required before any subsequent step can proceed.
- Secure a qualifying visa or residence permit. Common options for US citizens considering an NHR visa Portugal include the D8 digital nomad visa (for qualifying remote work arrangements), the D2 entrepreneur visa, or the Golden Visa program. Your chosen route must allow you to establish Portuguese tax residency.
- Register as a Portuguese tax resident at your local Finanças office by updating your tax address to your Portuguese residence. Tax residency is established when you spend 183+ days in Portugal during the calendar year or maintain a habitual residence there.
- Confirm your qualifying high-value activity documentation. For employed individuals, your employer must confirm through the Portal das Finanças that your role meets the applicable IFICI route criteria. For self-employed individuals, your professional activities must align with one of the 7 qualifying IFICI routes.
- Submit your IFICI application via the Portal das Finanças by 15 January of the year following your first year of tax residency. Example: become a tax resident in 2026, apply by 15 January 2027. Status is backdated to the start of your tax residency year.
- Receive confirmation from the Portuguese tax authority (AT) and begin filing Portuguese IRS returns at the 20% flat rate. After approval, keep documentation proving continued IFICI eligibility throughout the 10-year period. If your facts change or you no longer meet the requirements, report the change by January 15; depending on the IFICI route, the relevant entity or company may also have February or March reporting duties.
Before relocating, notify your US tax preparer so they can plan your FTC vs. FEIE strategy, FBAR filing obligations, and any catch-up filing needed from prior years. Our Streamlined Foreign Offshore Procedures guide is relevant if you have unfiled US returns.
Get expert help with your Portugal NHR US tax strategy
US citizens moving to Portugal under NHR 2.0 face complex dual-filing obligations that most local Portuguese accountants are not equipped to handle. IRS compliance requires command of Form 1116, FBAR, FATCA, and treaty provisions that fall well outside Portuguese tax practice.
TFX has helped thousands of US expats in Portugal optimize their tax position using the foreign tax credit, FEIE, and treaty provisions.
Get a free consultation today.
What happens to US taxes when NHR status ends after 10 years
When NHR or IFICI status expires after 10 years, Portuguese income tax reverts to the standard progressive rates of 13.25%–48%, plus a solidarity surcharge of 2.5% on income between €80,000 and €250,000 and 5% on income above €250,000 – which significantly changes the foreign tax credit calculation and may make Portugal less tax-efficient for US citizens.
After the 10-year period ends, your US filing obligations remain exactly the same. What changes is the Portuguese tax burden. At progressive rates up to 48% – plus applicable surcharges reaching an effective top rate of 53% for the highest earners – most US citizens in Portugal will pay more Portuguese tax than US tax on the same income. The FTC would then eliminate US tax liability on that income entirely, because the Portuguese tax paid exceeds the US liability. Total tax burden increases; the risk of double taxation decreases.
This is a significant shift from the IFICI period, where the 20% flat rate often left a residual US liability. The evolving dual taxation US Portugal policy debate is worth monitoring as it may affect long-term planning for US citizens with 10-year windows expiring in 2028–2033.
Streamlined filing procedures for US citizens who moved to Portugal without filing
US citizens who moved to Portugal under NHR but failed to file US tax returns can use the IRS Streamlined Foreign Offshore Procedures to catch up on up to 3 years of returns and 6 years of FBARs with no penalties, provided the non-compliance was non-willful.
To qualify for Streamlined Foreign Offshore (SFOP), you must have been outside the US for at least 330 full days in at least one of the 3 most recent tax years for which the US return due date has passed. You certify under penalty of perjury that your failure to file was non-willful. NHR holders who failed to file because they mistakenly believed NHR eliminated their US filing obligation generally qualify.
Understand the difference between the foreign and domestic streamlined tracks before filing. See how the Streamlined Domestic Offshore procedures (Form 14654) differ from the foreign track – the wrong track produces a very different penalty outcome. The IRS Streamlined Filing Compliance Procedures page confirms eligibility and the certification requirements.
Portugal NHR for retirees: Pension and Social Security taxation
Under NHR 1.0, foreign pension income was taxed at a flat 10% in Portugal – NHR 2.0 removed this pension benefit entirely, meaning US retirees receiving pension or IRA distributions now face standard Portuguese progressive rates of 12.50% to 48% unless they qualify under a specific IFICI professional activity.
The pension taxation Portugal expats experienced under NHR 1.0 was one of the regime's most-cited advantages. That 10% flat pension rate does not apply under IFICI. US retirees who did not secure NHR 1.0 status before 31 December 2023 will be taxed on pension income, IRA distributions, and 401(k) withdrawals at standard Portuguese progressive rates if they become Portuguese tax residents after that date.
For US Social Security paid to a US citizen living in Portugal, Article 20 allows the United States, as the paying state, to tax the benefit. The saving clause also preserves the US right to tax its citizens, so relief usually depends on treaty coordination and foreign tax credit treatment rather than a residence-only rule. The Social Security taxation guide for Americans living abroad covers the relevant rules in detail.
File your US expat taxes as a Portugal NHR holder
Portugal NHR and IFICI holders must file both Portuguese and US tax returns annually. Errors in Form 1116 foreign tax credit calculations can result in double taxation or IRS notices – and most local Portuguese accountants are not trained in US federal tax.
Taxes for Expats (TFX) specializes in US expat tax returns for Portugal NHR and IFICI holders. Our CPAs ensure your Form 1116, FBAR, and FATCA filings are accurate and optimized. Start your expat tax return today.
Frequently asked questions
Portugal NHR (Non-Habitual Resident) was a 10-year preferential tax regime offering a 20% flat rate on qualifying Portuguese income and broad exemptions on foreign-source income. The original regime closed to new applicants on 1 January 2024 and was replaced by IFICI (NHR 2.0), which targets qualifying professionals in innovation, technology, and research roles. Read our digital nomad visa guide for Americans in Portugal for visa options that work alongside IFICI registration.
The original NHR regime is closed to new applicants, but NHR 2.0 (IFICI) is fully active in 2026 for individuals who have not been Portuguese tax residents in the prior 5 years and who work in a qualifying high-value activity. Existing NHR 1.0 holders retain their benefits through the end of their 10-year window.
NHR 2.0, officially called IFICI, is Portugal's replacement for the original NHR regime, effective from 1 January 2024, offering a 20% flat tax rate on qualifying employment and self-employment income for up to 10 years. It restricts eligibility to professionals in technology, scientific research, startup roles, and select innovation sectors – not the broad "high added value" list of NHR 1.0.
US citizens must satisfy all 5 IFICI criteria: no Portuguese tax residency in the prior 5 years, a qualifying professional activity, a Portuguese NIF, tax residency registration, and an IFICI application submitted by 15 January of the following year. US federal tax filing obligations remain in full regardless of IFICI status.
Yes – US citizens must file US federal tax returns on worldwide income regardless of NHR or IFICI status. The foreign tax credit (Form 1116) is typically used to offset US tax with Portuguese taxes paid, often reducing or eliminating the US tax bill on Portuguese-source income. There is no NHR exemption from US tax obligations.
Form 1116 allows you to credit Portuguese income taxes paid against your US tax liability on the same income, dollar-for-dollar, potentially reducing your US bill to near zero on income taxed at Portugal's 20% NHR rate. The credit applies separately to each income basket – general income, passive income, and other categories are calculated independently.
The original Portugal NHR program ended on 31 December 2023, when it closed to new applicants. Transitional provisions allowed individuals who became tax residents in 2023 to apply for NHR 1.0 by 31 March 2024. IFICI (NHR 2.0) launched on 1 January 2024 as the active replacement. For expatriation-related tax questions, see our guide to relief procedures for certain former US citizens.
NHR was a broad preferential tax regime open to most new tax residents; IFICI (NHR 2.0) is its targeted replacement, limited to qualifying professionals in specific innovation and research sectors, with an application deadline of 15 January (vs. 31 March under NHR 1.0) and an annual proof-of-activity requirement that NHR 1.0 did not impose. IFICI also removes the 10% pension benefit that made NHR 1.0 particularly attractive to retirees.
