Portugal has long positioned itself as an attractive destination for foreign investment, entrepreneurship, and highly skilled professionals. In 2024, the country introduced a new tax framework aimed at reinforcing this strategy: the Incentive for Scientific Research and Innovation (IFICI).
2025 served as a testing year, during which the regime began gaining traction and its various possibilities were explored in greater depth as a driver of Portugal’s attractiveness.
Now, with a more solid track record and a settled procedural framework, IFICI has expanded its visibility and reinforced Portugal’s standing on the map as a competitive jurisdiction offering a very attractive tax framework for qualified professionals and entrepreneurs.
This regime offers significant tax benefits to highly qualified professionals who transfer their fiscal residence to Portugal and perform IFICI eligible activities for IFICI eligible entities.
Unlike previous regimes, most notably the Non-Habitual Resident (NHR) program, IFICI is more targeted, focusing on scientific research, innovation, technology, productive investment, and professions deemed essential to the country’s economic development.
For individuals planning to relocate to Portugal or companies looking to attract international talent, understanding these rules is crucial.
In terms of benefits, the IFICI regime stands out as the most attractive tax framework currently available in Portugal, since it introduces an exemption on foreign-sourced income which encompasses all income categories aside from pensions and income sourced in blacklisted jurisdictions for Portuguese purposes. Below you will find a detailed overview of the specific benefits available under this regime.
Eligibility: Who Can Benefit From IFICI?
To qualify for the regime, several conditions must be met:
- New Tax Residents: Only individuals who become fiscal residents in Portugal from 2024 onwards may apply. Additionally, they must not have been Portuguese tax residents during the previous five years.
- No Prior Regime Benefits: Taxpayers cannot have previously benefited from: the Non-Habitual Resident (NHR) regime, or the former residents’ incentive regime (“Programa Regressar”). IFICI may only be used once per taxpayer.
- Engagement in eligible professional activities: The regime applies exclusively to taxpayers carrying out highly qualified professional activities or members of statutory bodies.
- Relationship with an Eligible Entity: The taxpayer must hold an employment contract, serve as a member of a statutory body, or, in specific and limited circumstances, perform services for an eligible entity.
- Annual Eligibility: Taxation under IFICI is assessed on a yearly basis, requiring the taxpayer to remain a fiscal resident in Portugal and to continue earning income from an eligible professional activity to maintain the regime benefits.
Registration and Ongoing Compliance
- Taxpayers must apply for IFICI by January 15 of the year following the year they became residents or intend to benefit from the regime.
- Whenever the conditions to benefit from the IFICI regime, the taxpayer must inform the relevant certifying entity by January 15 of the following year.
Eligible Roles and Entities
IFICI is designed for individuals who contribute to Portugal’s economic and technological development. The eligible activities, as well as the corresponding conditions applicable to individuals and companies, are diverse and involve a level of analytical complexity that cannot be fully explored here. We highlight one scenario in particular.
Roles in Entities Certified by AICEP or IAPMEI
Job positions considered relevant for national economic development, productive investment or regional cohesion. The list of eligible professional positions is as follows:
- General and executive managers
- Administrative and commercial services directors
- Production and specialized services directors
- Directors in hospitality, catering, retail and other services
- Specialists in physical sciences, mathematics, engineering and related fields
- Medical doctors
- University and higher education professors
- Finance and accounting specialists
- Information and communication technology specialists
- Film, theatre, television and radio directors, producers and related directors
- Intermediate-level technicians and professionals in science and engineering
Additionally, in order to qualify, the employing entity must carry out at least one of the following economic activities:
- Extractive industries
- Manufacturing industries
- Electricity, gas, steam, hot and cold water and cold air
- Construction
- Accommodation, catering and similar activities
- Information and communication activities
- Financial and insurance activities
- Consulting, scientific, technical and similar activities
- Administrative and support service activities
- Education
- Human health and social support activities
We draw particular attention to the fact that the lists presented above (both in relation to job positions and to the employer’s activity) are based on other detailed and specific statutory lists that must be carefully reviewed on a case-by-case basis; reliance solely on the professional or corporate “title” referenced above is not sufficient to determine eligibility.
An additional note to the fact that, under this route, members of statutory bodies are also deemed as IFICI eligible in relation to the individual.
Those underlying lists have themselves been revised since the regime was first regulated. The regulating Ordinance, Portaria 352/2024/1, was amended by Portaria 52-A/2025/1 of February 25, 2025, and the IAPMEI list of qualified job positions now applies in the interpretative version issued by Aviso 9709/2025/2 of April 10, 2025. Any eligibility assessment must be run against the versions currently in force.
Although it is not possible to exhaustively list all scenarios provided for under the IFICI regime, it is important to note that additional categories exist, each subject to specific criteria, including:
- Higher Education, Science & Research
- Job positions and members of statutory bodies in Large Productive Investment Projects
- Highly qualified professions performed in companies with relevant investments that benefit or have benefitted from the Tax Regime for Investment Promotion (RFAI) or export-oriented businesses in certain industrial or services fields (at least 50% of turnover in exports)
- R&D Personnel Eligible for Fiscal Incentives
- Job positions and members of statutory bodies in Certified Startups
- Job positions or other professional activities carried out by residents in the Azores and Madeira: Madeira has now legislated on this route through Regional Legislative Decree 8/2025/M of December 30, 2025, which extends IFICI to taxpayers becoming fiscally resident in the region from January 1, 2026, provided they were not resident in Portuguese territory in any of the five preceding years and perform a highly qualified profession in an entity headquartered or with a permanent establishment in Portugal. The applicable professional and economic activity codes are still to be set by regional regulatory decree. The Azores have not yet legislated on this route.
In our day-to-day work with the regime, the range of eligible activities is broad enough to accommodate very different profiles. It reaches professionals relocating to take up a role with a Portuguese company, and equally founders and business owners who bring an operating activity to Portugal and hold a qualifying position within it. In both cases the reduced rates and exemptions set out below apply, provided the activity and the entity satisfy the statutory criteria in their own right.
Tax Benefits Under the IFICI Regime
The IFICI benefits are granted for a period of 10 consecutive years from the year of registration as a Portuguese tax resident onwards, being that one of the main attractions of the regime is its favorable tax treatment for a wide range of income streams as detailed below.
- Portuguese-Sourced Income: Income from employment or self-employment related to eligible activities is taxed at a flat rate of 20%, instead of the progressive scale that can reach a nominal rate of 53%. Social security contributions remain applicable. Other Portuguese-sourced income is taxed according to general rules.
- Foreign-Sourced Income: Foreign-sourced income, including employment, self-employment, dividends, interest, rental income and capital gains, is exempt from taxation in Portugal, although it must be reported in the yearly tax return. It is also worth noting that this may be an exemption with progression, which means that the exempt income increases the tax bracket applicable to income taxed under the general and progressive rates, which is not exempt or taxed under flat rates.
Exceptions apply:
- Pension income is fully taxable in Portugal at progressive rates (being extremely important to seek tax advice and see what should be deemed as pension income in Portugal; and what would be seen as capital or even employment income, therefore covered by the tax exemption).
- Income from tax havens should be taxed at a 35% flat rate.
The IFICI regime strengthens Portugal’s position as a competitive hub for innovation, technology and investment. By offering favorable taxation and targeting highly skilled professionals, the country aims to attract global talent capable of boosting scientific research and economic development.
For foreign individuals planning to relocate, and for companies looking to expand operations in / to Portugal, IFICI provides a clear and robust framework, but it requires careful assessment of eligibility and compliance.
Professional advice is essential to ensure not only that the applicant qualifies for the IFICI regime and complies with all the requirements and procedural steps applicable to each eligible scenario, but also that the client fully understands the Portuguese tax rules applicable to foreign-sourced income and the tax implications arising from any existing or planned foreign structures.
It should be noted that the IFICI regime does not override key tax principles and anti-abuse rules, including rules on place of effective management, controlled foreign companies (CFCs) and the General Anti-Abuse Rule (GAAR), among others.
To learn more, visit RME Legal’s website.
About the Authors:
Raquel Matos Esteves
Partner at RME Legal and committed to being a powerful ally in all projects she embarks. Passionate about analyzing each case from all angles and dedicated to providing clear and pragmatic advice. Before founding RME Legal, worked in Law Firms like SRS Legal, Tax consultancy Firms like EY, and Immigration Services, leading teams and international projects. Has wide experience with assisting Private Clients in all aspects of relocation processes, with a main focus on International Tax Consultancy, Compliance, and Litigation. Master’s Degree in Law and Management at Universidade Católica Portuguesa and Degree in Law at Faculdade de Direito da Universidade de Lisboa. Member of the Portuguese Bar Association.
Carlos Alcântara Neves
Senior Tax Consultant primarily focused on Personal Income Tax and International Taxation issues. The wealth management, structure optimization and residency planning of HNWIs are his main hub. Specialized in NHR and IFICI (“NHR 2.0”) regimes, namely advising on financial portfolios and tax risk analysis/assessment on local and international corporate structures as well as on its corresponding optimization for the purposes of the HNWI. Also adds a tremendous amount of experience in the preparation of the corresponding personal income tax returns. Before joining RME, provided tax consulting services in top tier tax law firms/boutiques as RPBA and RFF Lawyers. Holder of a Master’s degree in Tax Law from Universidade Católica Portuguesa and a Law degree from Faculdade de Direito da Universidade de Lisboa.
