The IFICI in Portugal: the special rate of 20 %, its conditions and the procedure

The IFICI is the Portuguese tax regime that replaced the Non-Habitual Resident (NHR) regime for new arrivals. It subjects net income from employment and self-employment of Portuguese origin to a special rate of 20% for 10 consecutive years, starting from the year of registration as a resident. It is reserved for individuals who have not been residents of Portugal in any of the previous five years and who are engaged in eligible activities. The application must be submitted via the Finance Portal by January 15th of the year following the acquisition of tax residency.

What Article 58-A provides

The IFICI (Tax on Capital Gains and Investments) is listed in Article 58-A of the Tax Benefits Statute (EBF), published on the Portuguese Tax Administration's Finance Portal. It was introduced by Law No. 82/2023 of December 29, 2023. The article page does not display a version date; it only shows the date of consultation. Review the text in force at the time of your decision.

IFICI and RNH

Paragraphs 8 to 12 of Article 16 of the Income Tax Code (CIRS), which contained the Non-Habitual Resident (NHR) regime, are reported as revoked by Law No. 82/2023. A doctrinal note from the administration (Despacho of July 17, 2026) indicates that the NHR remained in effect until December 31, 2023, and that the Finance Law for 2024 replaced it with the IFICI.

The comparison of the two regimes and the transitional provisions of the RNH are not detailed here.

Eligible activities

Paragraph 1 of Article 58-A lists the eligible activities, from a) to g):

• a) higher education and scientific research, including scientific employment, as well as positions and members of corporate bodies of entities recognized as centers of technology and innovation (Decree-Law No. 126-B/2021); ;
• b) skilled positions and members of social bodies, within the framework of contractual benefits for productive investment; ;
• c) highly qualified professions as defined by Portaria, in two cases: i) companies benefiting from investment support (condition assessed over the five preceding financial years); ii) industrial or service companies (listed CAE codes) which export at least 50% of their turnover, assessed during the financial year in which the functions began or one of the two preceding financial years; ;
• d) other qualified positions in entities recognised by AICEP or IAPMEI; ;
• e) research and development, for staff whose costs are eligible for the R&D tax incentive; ;
• f) positions in certified start-ups (Law No. 21/2023); ;
• (g) the posts or activities of tax residents in the Azores and Madeira, according to a regional legislative decree.

The definitions, thresholds, and list of highly qualified professions can be found in the text and in the Portaria. This page cannot determine whether your job or activity qualifies. An activity that appears similar to one of the listed cases may not meet the requirements of the text.

The condition of non-residence

The text requires that the beneficiary has not been a resident of Portugal in any of the previous five years. This condition is stipulated in Article 58-A. To determine if you meet this requirement, you must establish your residency history in Portugal over these five years, using the criteria outlined in Article 16 of the CIRS: more than 183 days in a 12-month period, or accommodation occupied under conditions suggesting an intention to make it your habitual residence. Our page on living in Portugal provides further details on these criteria.

The process: application and withholding tax

The deadline. The application must be submitted via the Finance Portal no later than January 15th of the year following the acquisition of tax residency. For tax residency acquired in 2026, the deadline is therefore January 15, 2027. A late application takes effect from the year in which registration is completed, for the remaining period: according to the administration's FAQ, for a resident since 2025 who applies in 2029, the scheme runs from 2029 to 2034.

The deposit. Portaria No. 52-A/2025, published in the Diário da República on February 25, 2025, amends Article 4 of Portaria No. 352/2024/1, which contains the IFICI regulations. It stipulates that the registration application must be submitted via the Finance Portal.

The retention of 20 %. For the 20 % withholding tax to be applied, proof of application submission must be provided to the employer. The tax authorities make the application status available before March 31st of each year.

What this page does not cover

• The treatment of foreign-source income under the IFICI (French tax regime for foreign income). The tax administration's FAQ addresses this, with a general rule, exceptions, and a list of jurisdictions determined by Portaria: read it.
• Details of exclusions from the scheme. The text specifically excludes beneficiaries of the non-habitual resident scheme or the option under Article 12-A of the CIRS, and the scheme can only be used once (paragraphs 10 and 12); the administration's FAQ also excludes those who have already benefited from the IFICI. See the text for other cases.
• The detailed list of eligible activities and the conditions for each category.
• The beneficiary's taxation excluding income from employment and self-employment activities: dividends, capital gains, real estate.
• The effect on the tax situation in France: tax residence, exit tax, tax treaty.

Numerical example (fictitious profile)

Situation. A French citizen, a hypothetical profile, moves to Portugal in 2026 to take up a management position. He has not been a resident of Portugal at any time during the previous five years. Let's assume, for this example, that his activity is eligible. He receives €150,000 in net employment income from Portuguese sources during the year.

Issue. He wants to know the tax represented by the special rate on this income, and when he needs to take action.

Strategy. He applies the 20 % rate to his net income from Portuguese sources. He submits his registration application on the Finance Portal and presents proof of submission to his employer.

Result. Applying the 20% % rate to €150,000 yields €30,000 for the year. The application must be submitted no later than January 15, 2027, since tax residency is acquired in 2026. This calculation is merely an illustration of the rate. It assumes eligibility, does not compare with the standard tax scale, and does not address income that is not from Portuguese sources.

What changes depending on your situation

• The eligibility of your activity, which is read in the text and in the portaria.
• Your residence history in Portugal over the previous five years.
• The date of acquisition of tax residence, which sets the deadline for the application.
• The nature and source of your income.
• Your situation in France: tax residence, assets, departure.

These elements are examined on a case-by-case basis. No tax result can be announced without this examination, and eligibility for the IFICI is never guaranteed in advance.