IFICI - the new Portuguese regime for non-habitual residents (RNH 2.0)

We are now fully in the era of NHR 2.0 (or “IFICI”). After almost a year of waiting, which coincided almost perfectly with the end of the transitional regime for NHR 1.0, the regulations governing NHR 2.0 were published at the end of 2024 and subsequently completed during 2025.

What benefits does the NHR 2.0 offer?

Before examining the details, let us briefly recap the main benefits available under NHR 2.0 for a period of 10 years:

• 20% personal income tax (PIT) rate on employment income (Category A) or self-employment income (Category B) derived from eligible activities;
• Tax exemption on foreign-source income, including employment income, interest, dividends, rental income and capital gains.

Pensions and income arising from tax havens (according to the Portuguese list) fall entirely outside the scope of the NHR 2.0 benefits. In addition, the regime is only available to individuals who have not been tax resident in Portugal in any of the previous five years.

NHR 2.0 - What has been regulated?

An initial regulation (Ministerial Order No. 352/2024/1 of 23 December, subsequently amended in 2025) established the registration process and the deadlines applicable to the various routes for accessing NHR 2.0.

It also established certain eligibility criteria. Our emphasis on “certain” is deliberate, since, at the time of publication, the regulations governing several other routes to NHR 2.0 remained pending. In fact, the Ministerial Order fully regulated only two routes:

1. Highly qualified professions carried out in companies with relevant qualifying investments under the RFAI (Tax Incentive Regime for Business Investment);
2. Highly qualified professions carried out in companies operating in certain industries or services and exporting at least 50% of their turnover in the tax year in which the NHR 2.0 beneficiary began performing their duties or in either of the two preceding years.

There is also a specific route for individuals who work for a certified start-up or serve on its corporate bodies, with the application submitted to Startup Portugal. The decisive criterion is the company’s certification as a start-up under Portuguese law, meaning that this route became operational upon publication of the Ministerial Order.

In practice, however, the broadest route proved to be another one, regulated in February 2025: qualified positions in entities carrying out economic activities recognised by IAPMEI or AICEP as relevant to the national economy (which, for simplicity, we refer to as the IAPMEI route).

It covers a wider range of professions and sectors, has lower qualification requirements and does not depend on the company’s export turnover.

For many applicants, it is also the most accessible route and will therefore be the focus of the following sections.

IFICI - What is a qualified position?

According to the list published by IAPMEI and AICEP, qualified professions include:

• Company directors (e.g. board members, chairpersons, chief executives, managers and managing directors)
• Administrative and commercial managers
• Production and specialist services managers
• Managers in the hotel, catering, retail and other services sectors
• Information and communication technology (ICT) specialists
• Specialists in the physical sciences, mathematics and engineering
• Doctors
• University professors
• Finance specialists, such as financial analysts and advisers (accountants are excluded)
• Directors, stage directors and producers in film, theatre, television and radio
• Mid-level technical staff in science and engineering

Applicants must hold at least the equivalent of Level 5 of the European Qualifications Framework (for example, a higher professional technical qualification or a university qualification). In the case of regulated professions, such as medicine, the specific professional access requirements must also be met.

There is no minimum experience requirement, making the IAPMEI route accessible to a much broader range of professionals.

Which companies are eligible for this specific route?

Unlike the route for exporting companies, there is no export requirement. It is sufficient for the entity in which the activity is carried out to engage in one of the economic activities recognised as relevant to the national economy, corresponding to the following CAE codes:

• Extractive industries (divisions 05 to 09)
• Manufacturing industries (divisions 10 to 33)
• Electricity, gas, steam, hot and cold water, and chilled air (division 35)
• Construction, specifically civil engineering (division 42)
• Accommodation (classes 5511 and 5512)
• Information and communication (divisions 58 to 63), including:
  • Publishing activities (may include books, newspapers, computer software)
  • Film, video and television programme production, sound recording and music publishing
  • Software programming activities
  • Software consultancy activities
  • Data processing, hosting and related activities
  • News agency activities
• Activities of holding companies and fund management companies (classes 6420 and 6630, with additional licensing requirements in the case of fund management)
• Activities of head offices (class 7010), architectural, engineering and related technical activities (division 71) and scientific research and development (division 72)
• Combined administrative support services (class 8211)
• Higher education (subclass 85420)
• Human health activities (subclasses 86100 to 86904)

Although CAE Revision 4 has already been implemented, the notices issued by IAPMEI and AICEP still follow CAE Revision 3, which should therefore be used as the primary reference.

The application is assessed by IAPMEI where the company’s consolidated annual turnover in the previous financial year was below EUR 75 million.

Above that threshold, or where the activity is carried out within a project recognised as being of Potential National Interest (PIN) or an Investment Project for Inland Territories (PII), responsibility lies with AICEP.

In either case, the application is submitted through the prospective beneficiary’s Portal das Finanças (the Portuguese Tax Authority online website).

How and when can I apply for the NHR 2.0 regime?

Applicants must submit their applications by 15 January of the year following the year in which they become resident in Portugal, a significantly shorter deadline than the 31 March deadline applicable under the old NHR.

For example, an individual who becomes tax resident in 2026 must submit the application by 15 January 2027. The authority responsible for assessing each application depends on the relevant NHR 2.0 route.

Some examples are set out below:

Which documents will I need to apply for the new NHR regime?

Applicants will be required to submit the following documents to the competent authorities:

• Copy of the employment contract (where applicable);
• Up-to-date permanent commercial registry certificate (where applicable);
• Copy of the grant agreement (where applicable);
• Evidence of the relevant academic qualifications;
• Declaration issued by the competent authorities confirming compliance with the requirements applicable to the activity performed.

It should be noted that the company in which the activity is performed will be required to demonstrate compliance with the applicable requirements by providing confirmation, by 15 February, through its reserved area on the Portal das Finanças (the Portuguese Tax Authority online website). The other competent authorities must also notify the Portuguese Tax Authority of the applications received by 15 February.

Finally, additional documents may be requested throughout the process, and the tax authorities must confirm NHR 2.0 status by 31 March of each year.

What is the best way to apply for NHR 2.0?

Our answer may sound like a commercial strategy, but it is not: the truth is that there is no single answer. The most appropriate route will depend on each taxpayer’s individual profile and on the company in which they will carry out their activity.

In our experience, a case-by-case assessment is always advisable, not only to maximise the prospects of a successful application, but also to ensure that there is a sound basis for maintaining the status throughout the regime’s ten-year period.

What can be said with certainty is that the various routes outlined above are now available, providing a sufficiently broad range of alternatives to support the regime’s objective of attracting talent to sectors regarded as critical, strategic or simply essential.

Is there a specific NHR 2.0 or IFICI for Madeira?

As regards NHR Madeira, Regional Legislative Decree No. 8/2025/M of 30 December established a regional regime for individuals who become tax resident in Madeira from 1 January 2026, have not been resident in Portugal during the previous five years and carry out a highly qualified profession.

The definition of the eligible professions and sectors of activity was left to a regional regulatory decree. In the meantime, the other routes for accessing IFICI apply directly in Madeira, meaning that individuals residing there do not need to wait for the regional regime to be implemented before applying.

Get expert support with your NHR 2.0 application

The conclusion: NHR 2.0 offers a highly competitive set of tax benefits, which are, in some respects, broader than those available under NHR 1.0, and which may be combined with other attractive features of the Portuguese tax system (pro tip: there is no Portuguese inheritance tax on assets located outside Portugal).

However, the application process is more complex and requires a greater exchange of information between applicants and the relevant companies: instead of the automatic approvals that characterised NHR 1.0, the regulations place clear emphasis on comprehensive eligibility checks from the application stage onwards, making the process potentially lengthy and complex.

Perhaps it is fair to say that with significant tax benefits come significant responsibilities.

Professional and experienced guidance is more important than ever.

NEWCO can support you at every stage of your journey towards NHR 2.0 through:

• Tailored and dedicated tax advice;
• Comprehensive assessment of eligibility for NHR 2.0, from both the applicant’s perspective and that of the company or investment;
• Analysis of qualified positions and highly qualified professions;
• Support throughout the application and registration process;
• Tax support from our certified accountants, providing expert guidance whenever you need it.