Tax Incentive for Scientific Research and Innovation (TISRI / IFICI / “NHR 2.0”)

Following the end of the Non-Habitual Resident (NHR) regime for new entrants, Portugal introduced a new targeted tax incentive aimed at attracting highly qualified professionals involved in scientific research, technology and innovation.

The Tax Incentive for Scientific Research and Innovation (TISRI) — also referred to as IFICI and commonly described as “NHR 2.0” — has been in force since 1 January 2024 and applies to individuals who become Portuguese tax residents from that date onwards and meet specific professional and activity-based criteria.

This Insight outlines how the regime operates, who may qualify and the practical considerations that should be addressed before relying on it.

What is IFICI / NHR 2.0?

IFICI is a Personal Income Tax (IRS) incentive regime designed to attract talent in areas considered strategically relevant to the Portuguese economy, in particular scientific research, technological innovation and other highly qualified activities.

Unlike the former NHR regime, IFICI is not a general relocation regime. Eligibility depends not only on tax residence status, but also on the exact activity performed in Portugal, often requiring formal recognition or certification by a competent public authority.

What tax benefits does the regime provide?

Eligible taxpayers may benefit from the following advantages:

• a flat IRS rate of 20% on Portuguese-source employment or self-employment income (Categories A and B) derived from qualifying activities, instead of the progressive IRS rates (which may exceed 45%, plus solidarity surcharges); and

• IRS exemption on all foreign-source income, with the exception of pensions and income sourced in blackilsted jurisdictions or tax havens. The exemption may cover, among others:

  • foreign employment income;

  • dividends and interest;

  • rental income; and

  • capital gains (including from shares, crypto-assets or real estate).

Importantly, this exemption applies without the need to confirm taxing rights under double tax treaties, which represents a material departure from the former NHR regime.

Who may qualify?

The regime may apply to individuals who:

• become Portuguese tax residents;

• have not been tax resident in Portugal during the previous five years; and

• carry out, in Portuguese territory, one of the qualifying activities expressly defined by law.

Which activities are covered under TISRI / IFICI?

Eligibility for the Tax Incentive for Scientific Research and Innovation (TISRI / IFICI) depends not only on becoming tax resident in Portugal, but also on carrying out one of the specific scientific, technological or highly qualified activities expressly listed in the law.

The regime is therefore activity-driven and depends on the verification of requirements or certification by different competent public entities.

The eligible activities are the following:

a) Higher education teaching, scientific research and roles in technology and innovation centres

This category covers:

• teaching activities in higher education institutions;

• scientific research roles; and

• functions carried out in recognised technology and innovation centres.

Competent entity: Foundation for Science and Technology (FCT)

b) Qualified roles within the framework of contractual tax benefits for productive investment

This category includes qualified jobs or management roles (including members of corporate bodies) linked to projects benefiting from contractual tax incentives for productive investment.

c) Highly qualified professions in RFAI or export-driven companies

To qualify under this category, the taxpayer must:

• hold a PhD, or a bachelor’s degree plus at least three years of professional experience; and

• perform a highly qualified profession under an employment or self-employment arrangement with a Portuguese company that:

  • benefits from the RFAI regime, or

  • exports at least 50% of its turnover; and

  • operates in an eligible industrial or services sector.

Highly qualified professions (Portuguese Classification of Professions – CPP):

• 112 – General managers and executive managers of companies

• 12 – Directors of administrative and commercial services

• 13 – Production and specialised services managers (except 1349)

• 21 – Specialists in physical sciences, mathematics, engineering and related technical fields (except 216)

• 2163.1 – Industrial or equipment product designer

• 221 – Medical doctors

• 231 – University and higher education teachers

• 25 – Specialists in information and communication technologies (ICT)

Eligible activity sectors (CAE):

• Extractive industries – divisions 05 to 09

• Manufacturing industries – divisions 10 to 33

• Information and communication activities – divisions 58 to 63

• Research and development in physical and natural sciences – group 721

• Higher education – subclass 85420

• Human health activities – subclasses 86100 to 86904

Competent entity: Portuguese Tax Authority

d) Other qualified professions in sectors recognised by AICEP or IAPMEI

This category applies to taxpayers who:

• hold at least post-secondary education relevant to the activity performed; and

• carry out a qualified profession under an employment or self-employment arrangement with a Portuguese entity operating in a sector recognised as relevant to the national economy.

Recognised professions (Portuguese Classification of Professions – CPP):

• 112 – General managers and executive managers of companies (including administrators and general directors)

• 12 – Directors of administrative and commercial services

• 13 – Directors of production and specialised services

• 14 – Directors of hospitality, catering, trade and other services

• 21 – Specialists in physical sciences, mathematics, engineering and related technical fields

• 221 – Medical doctors

• 231 – University and higher education professors

• 241 – Specialists in finance and accounting (excluding accountants, auditors, statutory auditors and similar)

• 25 – ICT specialists

• 265 – Film, theatre, television and radio directors, producers and stage managers

• 31 – Mid-level technicians and professionals in science and engineering

Recognised sectors (CAE):

• Extractive industries – divisions 05 to 09

• Manufacturing industries – divisions 10 to 33

• Electricity, gas, steam and air conditioning supply – division 35

• Construction – divisions 41 to 43

• Accommodation and food service activities – division 55

• Information and communication activities – divisions 58 to 63

• Financial and insurance activities – divisions 64 to 66

• Consulting, scientific, technical and similar activities – divisions 69 to 75

• Administrative and support service activities – divisions 77 to 82

• Education – division 85

• Human health and social support activities – division 86 (with statutory exclusions)

Competent entity: IAPMEI, I.P. or AICEP, E.P.E.

e) Research and development personnel eligible under SIFIDE II

This category covers R&D personnel whose costs qualify under the SIFIDE II tax incentive framework.

Competent entity: National Innovation Agency, S.A.

f) Roles in certified start-ups

Jobs or management functions carried out in certified start-ups recognised under the Portuguese start-up ecosystem framework.

Competent entity: Startup Portugal

g) Activities carried out in the Autonomous Regions of the Azores and Madeira

Jobs or other eligible activities carried out by tax residents of the Azores or Madeira, under region-specific rules.

Competent entities: Autonomous Regions of the Azores and Madeira

Registration and deadlines

The registration process depends on the activity performed. After completion of any required preliminary steps, the final registration application must be submitted to the Portuguese Tax Authority by 15 January of the year following the year in which Portuguese tax residence is acquired.

The application typically requires the submission of supporting documentation, which may include employment or service contracts, proof of qualifications and confirmations issued by public authorities or employers.

Why this matters

Although TISRI / IFICI / NHR 2.0 applies to a narrower group of taxpayers than the former NHR regime, it offers highly attractive tax benefits for those who qualify, particularly through the exemption of most foreign-source income.

In practice, however, access to the regime depends on meeting specific legal and technical requirements. Eligibility must be in place from the first day of Portuguese tax residence and is closely linked to how the activity is classified, how the professional relationship is structured and whether the relevant sector and professional codes are correctly aligned.

For this reason, TISRI should be assessed before relocation, as post-arrival adjustments may no longer be sufficient to secure access to the regime.

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This insight is provided for general information purposes only and does not constitute legal or tax advice. It is not intended to be an exhaustive statement of the law and shuold not be relied upon as a substitute for advice tailored to individual circumstances.

Enquiries may be directed to info@flegal.pt or via the Contacts section here.