Mauritius vs Portugal: Residency & Tax After NHR
For years Portugal’s Non-Habitual Resident (NHR) regime made it the default choice for Europeans seeking a sunny, low-tax base. That changed on 1 January 2024, when NHR closed to new arrivals, replaced by the much narrower IFICI incentive aimed at scientific research and innovation. Many people who would have chosen Portugal are now comparing alternatives — and Mauritius is high on the list.
Tax compared
| Mauritius | Portugal | |
|---|---|---|
| Headline personal income tax | 0%–20% | Progressive up to 48%, plus a solidarity surcharge (up to ~53% top) |
| Special expat regime | Remittance basis for non-domiciled residents (in force) | NHR closed to new entrants from 2024; narrow IFICI replacement |
| Capital gains tax | None | Yes — chargeable on gains |
| Inheritance tax | None | No estate tax, but 10% stamp duty on some transfers |
| Path to an EU passport | No (non-EU) | Yes — citizenship after ~5 years |
On pure tax, Mauritius is now the more efficient of the two for most new arrivals: a low flat-rate system and a remittance basis, versus Portugal’s standard rates now that NHR has gone. See our Mauritius taxation guide.
Residency and investment routes
Portugal’s Golden Visa still exists but its popular real-estate route was removed in 2023; qualifying now generally means an investment fund subscription (around €500,000) or similar, with a modest stay requirement. Mauritius offers a wider spread: property from USD 375,000, the retirement permit, occupation permits and the new Golden Visa for USD 1 million investors.
The real trade-off: EU citizenship vs tax and cost
Portugal’s decisive advantage is the EU: five years of residence can lead to a Portuguese — and therefore European Union — passport, with the freedom of movement that brings. Mauritius cannot offer that. What Mauritius offers instead is a materially lower tax burden, a lower cost of living, no capital gains tax, a common-law legal system and a warm island lifestyle year-round. If an EU passport is the goal, Portugal remains compelling despite the tax changes. If tax efficiency, cost and lifestyle lead your decision, Mauritius now looks stronger than it did when NHR was open.
We regularly help clients weigh the two; get in touch for a candid view on which fits your situation.
Is Portugal's NHR regime still available?
No. The Non-Habitual Resident regime closed to new arrivals from 1 January 2024, subject to narrow transitional rules, and was replaced by the IFICI incentive for scientific research and innovation. New movers can no longer rely on the classic NHR tax breaks.
Is Mauritius more tax-efficient than Portugal?
For most new arrivals, yes — Mauritius has a 0–20% personal tax scale, no capital gains tax and a remittance basis for foreign income, while Portugal now applies its standard progressive rates (up to around 53% at the top) to new residents without NHR.
Can I get a passport through Mauritius like I can through Portugal?
Not in the same way. Portugal offers a route to EU citizenship after about five years. Mauritius offers permanent residence and a longer path to citizenship, but it is not an EU member, so it cannot provide an EU passport.
Sources & further reading
Figures are summarised for general guidance and were correct at the time of writing; tax and immigration rules change, so we confirm the current position for your circumstances before you act.
More insights
Related reading
What the UK–Mauritius treaty covers — residence tie-breakers, dividends, interest, pensions and gains — and how it helps people and businesses.
How UK nationals are taxed after moving to Mauritius — leaving UK residence, UK-source income, the treaty and the Mauritian remittance basis.
The 183-day and 270-day tests, the domicile rule, the remittance basis for foreign income, and how to obtain a Tax Residence Certificate — explained clearly.
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