{"id":2020,"date":"2026-05-13T16:31:55","date_gmt":"2026-05-13T14:31:55","guid":{"rendered":"https:\/\/balmontconseil.com\/?p=2020"},"modified":"2026-08-13T15:38:20","modified_gmt":"2026-08-13T13:38:20","slug":"regime-ifici-portugal-2026","status":"publish","type":"post","link":"https:\/\/balmontconseil.com\/en\/blog\/regime-ifici-portugal-2026\/","title":{"rendered":"IFICI Portugal 2026 Regime: The successor to the NHR, conditions and actual taxation"},"content":{"rendered":"
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In summary\u2026<\/h2>\n

The IFICI (Incentivo Fiscal \u00e0 Investiga\u00e7\u00e3o Cient\u00edfica e Inova\u00e7\u00e3o) regime replaced the Non-Habitual Resident (NHR) regime in Portugal on January 1, 2024, following State Budget Law No. 82\/2023. It is significantly more restrictive than the previous NHR regime. It is aimed at individuals who transfer their tax residence to Portugal to work in sectors deemed to have high added scientific, technological, or innovative value. Eligible beneficiaries are taxed at a flat rate of 20% on Portuguese-source income derived from these activities and, in principle, benefit from an exemption on most foreign-source income for ten years. \n

\nThe scheme is no longer available to retirees with foreign pensions (the 10% tax exemption has been eliminated). For a French executive with substantial financial assets, the IFICI remains relevant only if the business activity carried out in Portugal falls within the list of eligible sectors, or if the asset profile can be structured to primarily generate passive income from foreign sources.<\/p>\n<\/div>\n\n\n\n

The transition from RNH to IFICI: what has changed<\/strong><\/h2>\n\n\n\n

The Non-Habitual Resident (NHR) scheme, created in 2009 and closed to new registrations on December 31, 2023, granted for ten years a flat rate of 20% on certain high-value-added Portuguese professional activities and a near-complete exemption on foreign-source income, including retirement pensions (taxed at 10% since 2020). It had made Portugal<\/a> a major destination for French, British and Nordic retirees.<\/p>\n\n\n\n

The IFICI scheme that replaces it retains the structure (20% tax rate, % for eligible local activities, conditional exemption on foreign income, 10-year term) but drastically tightens the eligibility criteria. It is no longer aimed at a general expatriate audience but specifically at those contributing to Portugal's national effort in research, technology, and innovation.<\/p>\n\n\n\n

Beneficiaries registered under the NHR scheme before December 31, 2023, retain their scheme until the expiration of their individual ten-year term. New arrivals from January 1, 2024, onwards can only apply for the IFICI.<\/p>\n\n\n\n

IFICI Eligibility Requirements<\/strong><\/h2>\n\n\n\n

Condition 1 \u2014 Transfer of tax residence to Portugal<\/h3>\n\n\n\n

The taxpayer must become a Portuguese tax resident as defined in Article 16 of the Income Tax Code (CIRS). The main conditions are: physical presence for more than 183 days over 12 consecutive months, or the availability of Portuguese accommodation used as a habitual residence.<\/p>\n\n\n\n

Condition 2 \u2014 Non-Portuguese tax residence in the previous 5 years. <\/h3>\n\n\n\n

The candidate must not have been tax resident of Portugal<\/a> during the five tax years preceding his application for registration in the IFICI regime.<\/p>\n\n\n\n

\"\"<\/figure>\n\n\n\n

Condition 3 \u2014 Carrying out an eligible activity <\/h3>\n\n\n\n

The activity carried out in Portugal must fall within one of the categories listed in the implementing texts: careers in scientific research and higher education (universities, recognized research centers), activities in industrial companies with high technological content, management positions in companies qualified as exporters, certain activities in sectors defined by decree (information technologies, biotechnologies, renewable energies, etc.).<\/p>\n\n\n\n

Condition 4 \u2014 Application within the deadlines <\/h3>\n\n\n\n

Registration for the IFICI scheme must be requested from the Autoridade Tribut\u00e1ria e Aduaneira (AT) no later than March 31 of the year following the transfer of residence. Failure to meet this deadline will result in the permanent loss of the scheme for a period of 10 years.<\/p>\n\n\n\n

Taxation applicable under the IFICI regime<\/strong><\/h2>\n\n\n\n
Income category<\/strong><\/td>IFICI regime<\/strong><\/td>Portuguese general law regime<\/strong><\/td><\/tr>
Employment income (eligible activities, source PT)<\/strong><\/td>20 % flat rate<\/td>Progressive scale up to 53 %<\/td><\/tr>
Targeted income (eligible activities, source PT)<\/strong><\/td>20 % flat rate<\/td>progressive scale<\/td><\/tr>
Dividends from foreign sources<\/strong><\/td>Exemption (subject to conditions)<\/td>28 % flat rate<\/td><\/tr>
Capital gains on securities from foreign sources<\/strong><\/td>Exemption (subject to conditions)<\/td>28 % flat rate<\/td><\/tr>
Foreign-sourced property income<\/strong><\/td>Exemption (subject to conditions)<\/td>Scale or 28 %<\/td><\/tr>
Foreign-source retirement pensions<\/strong><\/td>Normal taxation (NO exemption)<\/td>progressive scale<\/td><\/tr>
Income from Portuguese sources excluding eligible activity<\/strong><\/td>Common law regime<\/td>Common law regime<\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

The France-Portugal tax treaty<\/strong><\/h2>\n\n\n\n

The tax treaty signed on January 14, 1971, between France and Portugal, as amended by successive addenda, governs the allocation of taxing rights between the two states. For a Portuguese tax resident benefiting from the IFICI (French wealth tax on real estate):<\/p>\n\n\n\n