IFICI (NHR 2.0) in 2025: Requirements, Deadlines, and How to Apply

What is IFICI (Art. 58-A EBF)?

The Scientific Research and Innovation Tax Incentive (IFICI) grants a 20% flat tax rate on net income from employment (Category A) and self-employment (Category B) in eligible activities, for 10 consecutive years starting in the year the taxpayer becomes a Portuguese resident.

As a general rule, foreign-source income (Categories E, F, G, and A/B when applicable) is exempt, except when paid by entities located in jurisdictions considered tax havens, in which case a 35% tax applies.

⚠️ Note: Withholdings at 20% are advance payments. If the IFICI registration request is rejected, standard tax rules apply at settlement.

Who Can Benefit (General Conditions)

To qualify, taxpayers must:

Become a Portuguese tax resident in the year they wish to start the regime.
Not have been resident in Portugal during the previous 5 years.
Perform an eligible activity listed in Art. 58-A(1) EBF.
Remain resident throughout each year of application.
Earn income from eligible activities each year.
Not currently benefit (or have previously benefited) from NHR, the “Return Program” (Art. 12-A), or IFICI.

Eligible Activities and Entities (Quick Overview)

The regime covers several routes. The most relevant for private companies and qualified jobs are:

c) i) — Highly qualified professions + company with RFAI

Professions: listed in Annex I of Ordinance 352/2024/1 (e.g., CPP 112, 12, 13, 21, 221, 231, 25, 2163.1).
Minimum qualifications:
- PhD (level 8), or
- Bachelor/Master (level 6/7) + ≥ 3 years experience.
Entity: Company with “relevant applications” that benefited from RFAI (Investment Tax Credit, Chapter III CFI) in the year of employment start or in any of the 5 previous years.

c) ii) — Highly qualified professions + eligible CAE with ≥ 50% exports

Professions: same as Annex I (qualifications as above).
Entity: Industrial/service company with a CAE code from Annex II of Ordinance 352/2024/1 and ≥ 50% exports in the start year or either of the two previous years.
Note: Intra-EU supplies count toward the 50% threshold.

Other routes (a, b, d, e, f, g) cover teaching/research, contractual investment incentives (AICEP/IAPMEI), SIFIDE/ANI, startups (Startup Portugal), and regional regimes (Madeira/Azores).

❌ Exclusion: Jobs under Art. 22(2)(c) CFI (RFAI) are not eligible.

Employer Confirmations (AT Binding Ruling)

In binding ruling Proc. 28121, 14-07-2025, the Portuguese Tax Authority (AT) confirmed that a company with:

RFAI in any of the last 5 years,
CAE listed in Annex II, and
≥ 50% exports (including intra-EU),

meets the requirements for c) i) and c) ii). Employees becoming residents in 2024/2025 may therefore benefit from IFICI, provided they meet the personal conditions (profession/qualification/experience).

How to Apply (Tax Portal)

Deadline: By 15 January of the year after becoming resident (e.g., resident in 2025 → apply by 15-01-2026).
Where: Citizens → Services → Tax Benefits → IFICI Registration → Submit Request.
Late filing: Regime applies only from the filing year and for the remaining years of the 10-year period.

Typical documents:

Employment contract / commercial registry (board member) / research grant contract.
Academic qualifications (if required).
Employer declaration confirming activity requirements (applies to b, d, e).
For c): AT requests employer confirmation (via reserved area) by 15 March each year regarding:
- Compliance with c) i) or c) ii) criteria.
- Execution of highly qualified work by the beneficiary.

Who Reviews What

FCT: Research/teaching activities (a).
AT: Highly qualified jobs (c).
AICEP/IAPMEI: Investment contracts (b, d).
ANI: R&D incentives (e).
Startup Portugal: Startup routes (f).
AT: Residency and accumulation restrictions.

Withholding Tax and Annual Filing

Employer withholds 20% on Category A/B income upon proof of application.
In the annual return (Modelo 3), the taxpayer must also file Annex L (option for regime taxation).

FAQs (Quick Summary)

I have a Bachelor’s degree + 4 years of experience in an Annex I profession. Can I qualify via c) i)?
✅ Yes, if your company benefited from RFAI in the current or past 5 years.
My company exports 55%, mostly intra-EU. Does it count?
✅ Yes, intra-EU sales count toward the 50% export threshold.
I missed the 15 January deadline. Am I excluded?
❌ No, you can still apply later. The regime will apply from that year onward, for the remaining years (up to 10 total).
Are my foreign passive income streams exempt?
✅ Generally yes (Categories E, F, G, A/B where applicable).
❌ Exception: if paid from blacklisted jurisdictions → 35% tax applies.
If I change employer mid-period, do I lose IFICI?
❌ No, you keep it if you start another eligible job within 6 months and report it on the Portal.

How GoalSeek Can Help

IFICI pre-assessment (personal profile + company verification for c) i)/c) ii)).
Application dossier (documents, declarations, deadline tracking).
Payroll implementation (20% withholding and annual Annex L compliance).
International planning (tax treaties, foreign income exemptions, 35% exceptions).

👉 Book your IFICI Onboarding Session (€280 + VAT). If you move forward with registration, we credit 50% of this fee toward the service.

GoalSeek Pricing

Consulting: €280/session + VAT (minor follow-up questions included).
IFICI Registration / Activity Setup: from €1900 + VAT (depending on scope).
Tax Filing: €450/year + VAT.
Compliance Package: tailored (VAT, Social Security, Recapitulative, Annex L).

Legal Note

This article is for information purposes only and is based on binding ruling Proc. 28121/2025-07-14, Circular Letter 20276/2025, and official AT guides/FAQs (March 2025). Application of the regime depends on case-by-case verification of both taxpayer and entity requirements. Professional advice is strongly recommended before taking any decision.