João Santos Pinto
João Santos Pinto is a partner at CVSP Advogados, a law firm that assists with the IFICI | NHR 2.0.
Portugal introduced the IFICI
(Incentive for Scientific Research and Innovation) in 2024, also known
as NHR 2.0, to replace the former Non-Habitual Resident program. The
regime is designed to attract international professionals, researchers and
entrepreneurs working in high value-added and innovative fields.
To qualify for IFICI, applicants
must become Portuguese tax residents by spending more than 183 days in Portugal
per year or having a permanent home here, must not have been tax residents in
Portugal in the previous five years, and must perform an eligible activity in
scientific research, innovation or another high value-added sector listed by
the government. An application must also be filed after registering as a
resident taxpayer.
Under IFICI, qualifying income
from employment or self-employment is taxed at a flat 20% rate,
significantly lower than Portugal’s standard progressive tax brackets which can
reach 48%. Certain categories of foreign-source income, including business
profits, employment income, royalties, dividends, interest, rents and capital
gains, may benefit from exemption in Portugal as long as they are not
considered Portuguese-sourced and do not originate from jurisdictions included
on Portugal’s blacklist.
Pensions, however, are generally
excluded from the IFICI regime. Only in very specific cases might certain
types of private pensions potentially qualify, and this always requires a
careful case-by-case analysis of the applicable double tax treaty and the
nature of the pension scheme.
The status is granted for 10
consecutive years, providing stability and predictability for long-term
planning. With its combination of tax efficiency, strategic location in Europe
and quality of life, IFICI, also referred to as NHR 2.0, strengthens Portugal’s
position as a leading destination for global talent and innovation.
As with any tax regime, each case
must be assessed individually to confirm eligibility and the effective benefits
available.
