Key takeaways
- The Tribunal de Contas counts 946 IFICI registered taxpayers in May 2026, up from 147 in 2024 and 799 in 2025. The figure counts registrations, not approvals.
- NHR had 128,958 registered taxpayers at the end of 2024, about 136 times IFICI's 946 (derived, different dates; IGF audit and Tribunal de Contas).
- Only 82 taxpayers showed an IFICI benefit in the 2025 accounts, at about €1.5 million, against €2,099 million of NHR tax expenditure (Observador and ECO; Tribunal de Contas).
- Registrants are 75.6% directors, managers or ICT specialists and 11.3% university teachers or researchers; 65.9% live in Lisbon and 89.3% are foreign nationals (Tribunal de Contas).
- IFICI taxes Portuguese-source employment and self-employment income from listed activities at 20% for ten years. Foreign income is exempt in general, with pensions (category H) excepted (Autoridade Tributária FAQ and circular).
- The source law is Lei 82/2023, not Lei 31-A/2024 as our own research brief stated; the detail sits in Portaria 352/2024/1 of 23 December 2024.
- Retirees, landlords and remote workers paid from abroad have no listed activity; the Tribunal says the law does not define highly qualified professions or economically relevant activities adequately.
- No approvals, refusals, route split, processing time or cost forecast has been published; the Inspeção-Geral de Finanças plans an IFICI assessment for 2027.
On the Tribunal de Contas's count, 946 taxpayers had registered for IFICI, the regime widely called NHR 2.0, by May 2026. The regime it replaced, NHR, had 128,958 registered taxpayers at the end of 2024. That is about 136 NHR registrants for every IFICI registrant, comparing figures from different dates (derived).
The gap follows from the design. NHR was open to almost anyone who moved to Portugal after five years abroad. IFICI applies a 20% rate to Portuguese-source salary and self-employment income, and only for people in listed activities: university teaching and research, certified startups, qualified jobs at companies with investment contracts or export profiles, and highly qualified professions in a defined list of industries. Retirees, remote workers paid from abroad and landlords fall outside it. The Tribunal found that 75.6% of registrants are directors, managers or ICT specialists, and only 11.3% are university teachers or researchers, the group the regime's full name suggests.
The count is also thinner than it first looks. It measures registrations, not approvals. Only 82 taxpayers showed a benefit in the accounts for 2025, at a cost of about €1.5 million, against €2,099 million of tax expenditure on NHR in the same accounts. Nobody has published how many registrations were accepted, refused or dropped, and the Tribunal says the law does not define its own key terms well. This article sets out who qualifies, what the 20% covers, what the numbers show and which popular claims fail against the primary texts, including one from our own research brief.
Where the law sits
The official name is Incentivo Fiscal à Investigação Científica e Inovação, shortened to IFICI. "NHR 2.0" is a trade nickname that no law uses. The source law is Lei 82/2023 of 29 December, the 2024 State Budget, which added article 58-A to the Estatuto dos Benefícios Fiscais. Our research brief named Lei 31-A/2024 as the source. That is wrong, and the tax authority's own page for article 58-A shows Lei 82/2023 as the only amending act.
The detail sits in Portaria 352/2024/1 of 23 December 2024, which lists the eligible professions and activities and the bodies that certify them. It entered into force the next day and applies to people who became Portuguese tax residents from 1 January 2024. Portaria 52-A/2025/1 of 25 February 2025 added a rule that requests and changes go through the Portal das Finanças. The tax authority's Ofício-Circulado 20276/2025 of 26 February 2025 explains the procedure, and Despacho 24/2025-XXIV of 21 February 2025 set transitional dates for the first cohort.
We found no amendment to article 58-A on the mainland through October 2026. The authority's page lists none, and a law-firm summary of the 2026 State Budget does not mention IFICI. The 2027 budget proposal reached Parliament on 8 October 2026, with a final vote scheduled for 24 November. One secondary source says IFICI is unchanged in it. We did not read the articles of the proposal ourselves.
Madeira has its own version. The regional budget for 2026, Decreto Legislativo Regional 8/2025/M of 30 December 2025, applies to people who become Madeira tax residents from 1 January 2026, were not resident in Portugal in the previous five years and work in a highly qualified profession for an employer based in Portugal. The profession and activity codes depend on a later regional decree, and we could not confirm that it exists. We could not read an Azores equivalent.
Who qualifies: one test and seven routes
Every applicant must pass the same general test. They become Portuguese tax residents in the year the regime starts, they were not resident in any of the previous five years, they have never used NHR or IFICI, and they have not opted for the Programa Regressar. The benefit can be used once. From 2025 it cannot be combined with IRS Jovem. The look-back is five years.
On top of that test, the work must fall into one of the routes in article 58-A. Each route has a body that certifies it, which is why the employer or institution is part of the application and not only the individual.
| Route | Who qualifies | Certifying body |
|---|---|---|
| a | Higher-education teaching and scientific research | FCT |
| b | Qualified jobs and board posts at firms with contractual productive-investment benefits | AICEP |
| c | Highly qualified professions at firms with relevant RFAI tax aid, or at industrial and service firms exporting at least 50% of turnover | Tax authority |
| d | Qualified jobs and board posts at entities recognised as relevant to the national economy | AICEP or IAPMEI |
| e | R&D staff whose costs qualify for business R&D incentives | ANI |
| f | Jobs and board posts at startups certified under Lei 21/2023 | Startup Portugal |
| g | Regional activities in the Azores and Madeira under regional decrees | Regional decrees |
Two thresholds define a highly qualified profession in the Portaria. The person needs a qualification at level 8 of the European Qualifications Framework, or level 6 plus three years of proven experience. The profession must also appear in Annex I, which lists chief executives (code 112), administrative and commercial services managers (12), production and specialised services managers (13), science, mathematics and engineering specialists (21, except 216), industrial and equipment product designers (2163.1), doctors (221), university teachers (231) and ICT specialists (25). Annex II lists the activities of the employer: mining and quarrying (divisions 05 to 09), manufacturing (10 to 33), information and communication (58 to 63), physical and natural science research (group 721), higher education (85420) and human health (86100 to 86904).
Hotels and restaurants are divisions 55 and 56. They sit outside the Annex II ranges we read, so hospitality staff would need another route, such as a certified startup. Our summary of the annexes comes from the authority's copy of the Portaria read through a summarising tool, because the Diário da República viewer would not load. Check the codes against the original before relying on them.
The people the regime excludes matter as much as those it admits. Pensioners and landlords have no listed activity. Former NHR and IFICI users and anyone resident in the past five years fail the general test. Digital nomads and remote workers paid by foreign employers are not named in the law, and the 20% rate applies only to Portuguese-source employment and self-employment income from a listed activity, so they would have nothing to apply it to. That last reading is ours. The authority has not published a statement about digital nomads. Our D8 visa analysis covers the visa that remote workers do use.
What the 20% covers, and what it does not
The rate is 20% on net category A income (employment) and category B income (self-employment) of Portuguese source, earned from the qualifying activity, for ten consecutive years from the registration year. The taxpayer may choose to aggregate the income with other earnings instead. Employers withhold 20% once the request has been submitted. If the employee cannot show proof of submission, the employer withholds at the general rates.
Foreign-source income is treated differently. The authority's FAQ gives the general rule as an exemption from IRS, with an exception for category H, which is pensions. Income paid from entities in a jurisdiction on the official list of clearly more favourable tax regimes is taxed at 35%, and the circular's example is dividends from the United Arab Emirates. The authority's documents we read do not discuss foreign pensions in so many words. Reading the category H exception, a foreign pension is taxed under the ordinary IRS rules. That is our reading, and it is the point where many online guides disagree with the authority.
The ten years run consecutively. A new qualifying activity that starts within six months of the last one keeps the benefit, and an unused benefit can resume for the remaining years. A lapse does not restart the clock. Because the benefit can be used only once, losing it is permanent.
| Feature | IFICI | NHR (old regime) |
|---|---|---|
| Rate on Portuguese earned income | 20% on net category A and B income from a listed activity | 20% for listed high-value-added activities; other income at general rates |
| Foreign-source income | Exempt in general; pensions (category H) excluded; 35% on income from listed low-tax sources | Broad exemptions; foreign pensions at 10% for later entrants (secondary source) |
| Who can enter | Listed, certified activities; not resident in the previous 5 years | Almost anyone not resident in the previous 5 years |
| Duration | 10 consecutive years, once only | 10 years |
| Open to new entrants | Yes, for tax residents from 1 January 2024 | No since 1 January 2024; transitional route closed 31 March 2025 |
| Registered taxpayers | 946 (May 2026) | 128,958 (end-2024) |
| Tax expenditure | About €1.5 million, 82 users (2025 accounts) | €2,099 million (2025 accounts) |
NHR ended for new entrants on 1 January 2024. People already registered keep it for their ten years. A transitional route let some 2024 arrivals register if they were resident by 31 December 2024 and could show a visa or residence permit valid to 31 December 2023, a lease or reserved property by 10 October 2023, a school enrolment by 10 October 2023, or an employment contract by 31 December 2023. The deadline for those people was 31 March 2025, and the Inspeção-Geral de Finanças puts the end of the transitional regime at 31 December 2033. We found no count of how many people used it. Our D7 visa analysis tests the claim that D7 holders can still register.
How to register, and the dates that matter
The request must be filed on the Portal das Finanças by 15 January of the year after the person becomes resident. Someone who became resident in 2026 therefore has until 15 January 2027 (derived). Filing late is allowed, but the benefit then runs only for the years that remain. The circular's own example is a person resident from 2025 who registers on 10 January 2029 and receives 2029 to 2034, which is six years.
The annual cycle is fixed. The certifying entities report to the tax authority by 15 February. The authority asks employers to confirm the facts by the end of February, and employers answer by 15 March. The authority shows the registration status in the taxpayer's reserved area by 31 March. For the first cohort, who became resident in 2024, Despacho 24/2025-XXIV moved the dates back: requests by 31 March 2025, entity confirmation by 30 April and the authority's information by 15 May.
The documents depend on the route. They include an employment contract, a company certificate for board members, a scholarship contract or proof of academic qualifications. The science foundation FCT, which certifies the research and teaching route, gives ten working days to complete a missing document. The tax authority alone decides on the benefit. We found no official processing time and no appeal procedure specific to IFICI, so the "30 to 90 days" quoted by a property consultant has no source.
The first cohort started late. Portaria 352/2024/1 appeared on 23 December 2024. A month later Observador reported that the professions lists and the official request form were still missing and that a government source described applications as few, without a number. That helps explain why the earliest count is small.
IFICI does not touch the citizenship clock. Under Lei Orgânica 1/2026, in force since 19 May 2026, nationality needs ten years of legal residence, or seven for EU and CPLP nationals, counted from the first valid residence permit. Our nationality law analysis sets out that rule. A tax regime neither shortens nor lengthens it.
946 registrations: the only official count
The Tribunal de Contas published the count in its opinion on the 2025 State Accounts, delivered to Parliament on 29 September 2026. It reports IFICI registered taxpayers, called inscritos, at 147 for 2024, 799 for 2025 and 946 in May 2026. The Tribunal's text gives no reference date for the first two figures. We read them as cumulative registrations. If that is right, 2025 added 652 and the first five months of 2026 added 147 (derived). Registrations bunch before the 15 January deadline, so a part-year figure is not comparable with a full year.
The NHR comparison comes from the same opinions and an audit. The Tribunal and the Inspeção-Geral de Finanças put NHR registrants at 41,229 in 2019, 57,887 in 2021, 74,258 in 2022, 114,645 in 2023 and 128,958 in 2024. In 2023 alone 40,387 people were admitted, which lifted the stock by 54.4%. The next table sets the two regimes side by side with the cost the State Accounts attach to NHR.
Two cautions apply. The 946 counts people who registered, and the reporting notes that not all registrants opted into the regime. It does not count approvals, refusals or people who dropped out. The Tribunal's PDF is robots-blocked to our fetch tool, so we read the 147, 799 and 946 through its copy hosted by the broadcaster RTP, and the nationality shares and the cost through Observador and ECO, both dated 29 September 2026.
A separate audit confirms the gap in public knowledge. The Inspeção-Geral de Finanças reviewed NHR in Report 103/2025, approved on 29 April 2026. Its recommendation 2.3 asks for an in-depth assessment of IFICI. The audit says the regime is too recent for a cost-benefit analysis and plans to consider it in 2027. On 23 October 2026 a news outlet was still writing that it is not yet known how many new residents benefit.
Who the 946 are
The Tribunal's profile of registrants is specific. Foreign nationals are 89.3%. Directors, managers and ICT specialists are 75.6%. University teaching and research is 11.3%. People aged 36 to 55 are 59.2%. The share living in Lisbon is 65.9%. By nationality Observador lists Brazil at 12.1%, Russia at 10.1%, France at 7.5%, the United Kingdom at 7.1%, the United States at 7.0%, Germany at 6.4%, Portugal at 5.9% and Spain at 5.1%.
Those shares do not reconcile on their face. If 89.3% are foreign, 10.7% are not, yet Portuguese nationals are 5.9%. The remaining 4.8 points may be dual nationals or unknown nationality, but we could not check, because the detail sits in a box and an annex of the opinion that we could not read. We report both figures as published.
The profile answers a question the regime's name invites. IFICI is sold as an incentive for research and innovation. Registrants are mainly corporate managers and technology staff in Lisbon, and researchers and teachers are about one in nine. The Tribunal adds that the law does not adequately define "highly qualified professions" or "economically relevant activities", and that some listed categories carry no minimum qualification level. We did not see the full sentence, only the summary.
Lisbon's weight matches the concentration of other residency flows. Our foreign residents analysis found no verified count for D7, D8 or IFICI holders. This is now the one of the three with an official number, and its holders cluster in the capital where our Lisbon tourism statistics show an airport already at its capacity ceiling.
The cost: €1.5 million against €2.1 billion
The Tribunal reports that 82 taxpayers showed an IFICI benefit in the 2025 accounts, at a total cost of about €1.5 million, an average of €18,642 per taxpayer measured against the tax they would have paid as ordinary residents. The accounts relate to 2024 income, which is the year of the first cohort. Eighty-two is 55.8% of the 147 registered for 2024 (derived, and only a rough ratio because the registration date of the 147 is not stated). The 82 and the €1.5 million rest on the press reports. We did not find them in the part of the PDF we could read.
NHR cost far more. The tax expenditure the State Accounts attach to NHR was €619.7 million in 2019 according to the Inspeção-Geral de Finanças, €1,360 million in 2022, €1,297 million in 2023, €1,741 million in 2024 and €2,099 million in 2025. The 2024 figure is up 34.3% on 2023. NHR is close to two-thirds of all IRS tax expenditure: 63.9% of the €3,286 million that ECO reports for 2025 (derived). The 2022 figure is an estimate built on 29,426 declarations out of about 33,000 filed.
Three bases circulate for 2023 and they should not be mixed. The State Accounts give €1,297 million on a settlement-year basis. The tax authority's 2023 expenditure report gave €1,229.6 million. Its later report gave €1,541.3 million for a narrower line, the high value-added article only, on an economic-year basis. For 2025 the authority's economic-year figure is €1,824.4 million against the Tribunal's €2,099 million. We use the State Accounts series for continuity and name the basis.
The benefit is concentrated. The 50 largest of 48,723 declarations in 2024 account for €421.3 million, or 24.2% of NHR tax expenditure. The Inspeção-Geral de Finanças also found indications that 71 taxpayers, in 254 situations, breached the five-year non-residence rule. On the other side of the ledger, the same audit puts tax revenue from NHR taxpayers at €788.6 million in 2023, up from €275.3 million in 2019 (+186.5%), excluding property taxes and VAT. A former Secretary of State for Tax Affairs estimated the net positive effect at no less than €2 billion. That is his estimate, not an official one.
IFICI has not yet produced a comparable record. The Tribunal expects its cost to rise significantly as registrations grow. We found no budget estimate of its cost in the 2024, 2025 or 2026 budget documents we could reach, and the absence of a forecast is a gap in our search rather than proof that none exists.
Why the number is small
Registration needs a listed activity, a qualification, an employer or institution that confirms the facts and a deadline that falls in January. The first cohort also faced a regulation that arrived on 23 December 2024 and a form that was not ready a month later. Those are the mechanisms the sources document.
A scale check helps, with limits. Eurostat's table of first permits for remunerated activities by reason shows 1,879 permits for highly skilled workers in Portugal in 2019, 2,919 in 2022, 4,377 in 2023 and 2,718 in 2024. Researchers add 14 to 274 a year and the EU Blue Card under 30. These are non-EU nationals receiving a first permit in a year. IFICI registrants include EU citizens who need no permit and exclude many highly skilled permit holders whose job is not on the lists. The comparison shows only that 946 registrations over two and a half years are the same order of magnitude as one year of highly skilled work permits. The 2025 entry for total employment permits in the dataset, 240,523, is flagged by Eurostat as a break in series. We do not compare it with earlier years.
The population of eligible people is not published. No source gives the number of foreign managers, ICT specialists and academics who moved to Portugal after five years abroad. Without that denominator, nobody can say whether 946 is a low take-up or a close fit to a narrow eligible group.
Eleven claims, tested
Most online guidance on IFICI is law-firm marketing and relocation advice. Our research read the main pages that rank for the regime's names. One of them contradicts itself on whether remote workers qualify. One quotes an approval timeline from a page dated in January 2027, which is in the future. The panel below tests eleven claims against the primary texts. Several of them fail because they describe the old NHR, and one comes from our own research brief.
The pattern is consistent. Most wrong claims about IFICI are accurate descriptions of NHR, quoted after NHR closed. The 20% rate, the ten years and the foreign-income exemption carried over. Almost everything else changed: who is eligible, what counts as eligible work, how the benefit is proven and what happens to foreign pensions.
How IFICI compares with other residency numbers
The table below sets IFICI against the other residency numbers in this series. They count different things, in different periods, and they do not add up. Their value is in showing what each figure measures. The 946 IFICI registrations are smaller than the 2,685 golden visas granted in 2025 and the 2,718 highly skilled first permits of 2024. They are about a fifth of the 4,472 D8 visas issued up to about June 2024 (derived, different periods) and a fraction of one percent of the 1.59 million foreign residents. The D8 count is the last official figure for that visa. Our golden visa statistics describe a route whose investment totals stopped being published in 2023.
Comparable regimes elsewhere also tend to be small, and few countries publish counts. The table below lists employment-linked and foreign-income regimes with the beneficiary counts we found. Spain and Greece publish none that we could locate. Italy's flat tax for new residents had 94 beneficiaries in 2017 and 2,468 in 2025 according to a study reported by Milano Finanza, a secondary source. Ireland's special assignee relief had 2,658 claimants in 2024, according to the Revenue Commissioners' report, which is provisional. IFICI's 946 is smaller than both but within a factor of three, for a regime in its third year.
| Regime | Headline terms | Duration | Beneficiaries found |
|---|---|---|---|
| Portugal IFICI | 20% on Portuguese-source A and B income from listed activities | 10 years | 946 registered (May 2026) |
| Spain, Beckham regime | 24% up to €600,000, 47% above (secondary source) | Up to 6 tax years | None found |
| Italy, flat tax on foreign income | €200,000 a year from August 2024; €300,000 for 2026 arrivals reported as enacted by one source and as a draft by another | Not confirmed | 2,468 in 2025 (94 in 2017), study via Milano Finanza |
| Greece, article 5C | 50% exemption on Greek employment and business income | 7 years | None found |
| Netherlands, 30% ruling | 30% tax-free allowance, 27% from 1 January 2027 | 5 years | None found |
| Ireland, SARP | 30% relief on income between €100,000 and €1 million | Up to 5 years | 2,658 claimants in 2024 (provisional) |
The foreign terms come from secondary sources, and Italy's figures conflict between sources. Treat the table as a map of where to look, and check the primary instrument for any decision.
What this means for travelers, businesses and analysts
Travelers. IFICI has no effect on visitors, and a holiday starts no residency or tax clock. For someone scouting a move, the finding is practical: the regime follows a job or a certified company, so the search starts with an employer and not with a property. About two in three registrants live in Lisbon. For that city, see our Lisbon travel guide.
Tourism businesses and investors. Hospitality and food service sit outside the activity ranges we read, so hotel and restaurant staff are not the intended beneficiaries. A demand thesis for housing or hotels cannot rest on 946 registrations and 82 users, and we found no sourced evidence linking IFICI to rents, prices or the hospitality workforce. Employers in eligible sectors face an annual confirmation cycle with 15 February and 15 March deadlines. The thresholds that would change this assessment are a published count of approvals and refusals, the Tribunal's detailed box on IFICI, the Inspeção-Geral de Finanças assessment planned for 2027, and the budget vote of 24 November 2026.
Journalists and analysts. The citable figures are 147, 799 and 946 IFICI registrations (Tribunal de Contas, May 2026), 128,958 NHR registrants at the end of 2024, NHR tax expenditure of €2,099 million in 2025 and the registrant shares of 75.6% managers or ICT and 11.3% teachers or researchers. The 82 users and €1.5 million come from press reports of the same opinion. Do not repeat that NHR 2.0 is open to everyone, that pensions are exempt, that Lei 31-A/2024 created IFICI, that 39,909 people held NHR at the end of 2023, that the first approvals came in March 2026, or that approval takes 30 to 90 days. The finding this article adds to the series is a rare official count that measures registration and stops there: there is still no published number for approvals, refusals, routes, or the cost forecast.
Data & sources
Period covered: 2019 to October 2026 (IFICI from 2024)
- Tribunal de Contas, Parecer sobre a Conta Geral do Estado 2025 · IFICI registrations (147, 799, 946) and registrant profile; NHR tax expenditure 2025 Accessed 25 Oct 2026.
- Observador, 29 September 2026 · IFICI registrations by nationality and the cost for 82 taxpayers Accessed 25 Oct 2026.
- ECO, 29 September 2026 · IFICI series, 82 taxpayers and total tax expenditure 2025 Accessed 25 Oct 2026.
- Autoridade Tributária, article 58-A EBF · Legal text summary of the IFICI regime and amending act Accessed 25 Oct 2026.
- Portaria 352/2024/1 (Autoridade Tributária copy) · Eligible professions, activities, certifying bodies and procedure Accessed 25 Oct 2026.
- Portaria 52-A/2025/1 (Autoridade Tributária copy) · Amendment routing requests through the Portal das Finanças Accessed 25 Oct 2026.
- Ofício-Circulado 20276/2025 · Procedure, deadlines, foreign income and pensions treatment Accessed 25 Oct 2026.
- Autoridade Tributária, IFICI frequently asked questions · Duration, foreign income, registration deadline Accessed 25 Oct 2026.
- IGF, Report 103/2025 synthesis · NHR 2019 and 2024 stock and cost, revenue, rule breaches, IFICI recommendation Accessed 25 Oct 2026.
- Observador, 3 October 2023 · NHR registrants 2021 and 2022 and 2022 cost Accessed 25 Oct 2026.
- Tribunal de Contas, Parecer CGE 2024, executive summary · NHR cost 2024 and 2023 comparison Accessed 25 Oct 2026.
- OCC, Guia Prático IFICI, March 2025 · Practical summary of eligibility, annexes and dates Accessed 25 Oct 2026.
- Observador, 23 January 2025 · Missing lists and request form at the start of the first cohort Accessed 25 Oct 2026.
- Eurostat, migr_resocc · First permits for remunerated activities by reason, Portugal Accessed 25 Oct 2026.
- Irish Revenue, SARP report · Special assignee relief claimants and cost Accessed 25 Oct 2026.
Methodology
This article uses the Tribunal de Contas opinion on the 2025 State Accounts, the Inspeção-Geral de Finanças audit of NHR, the tax authority's pages, circular and the two Portarias, the OCC practical guide, Eurostat's permit tables, and press reports of the Tribunal's opinion from Observador and ECO. The Tribunal's PDF could not be fetched directly, so its IFICI figures were read through a copy hosted by RTP. The Diário da República viewer would not load, so legal wording comes from the tax authority's copies, read through a summarising tool; none of it is a verbatim quotation.
Five limits govern the article. The 946 counts registrations, not approvals or beneficiaries. The 82 users and the €1.5 million come from press reports, because we could not find them in the part of the PDF we read. The reference dates of the 147 and 799 are not stated. No count of the eligible population exists. Foreign comparators rest on secondary sources, and we found no beneficiary count for Spain or Greece.
Where sources disagree we publish both values: NHR cost for 2023 on three bases, the 39,909 and 114,645 NHR counts, and the 89.3% foreign share against the 5.9% Portuguese share. Claims that failed against the primary texts are named in the corrections panel, including Lei 31-A/2024 from our own research brief. Derived figures are marked as derived.
Notes on the data
Not published: IFICI approvals, refusals, route split, processing time, cost forecast, the eligible population, the number of people who used the NHR transitional route, the NHR registration count for 2025, and beneficiary counts for Spain's and Greece's regimes. The Tribunal's box on IFICI and annex E3 were not read.
Contested or unreconciled: NHR 2023 cost is €1,297 million (State Accounts), €1,229.6 million (tax authority report for 2023) and €1,541.3 million (narrower line, economic-year basis). NHR 2025 cost is €2,099 million (Tribunal) or €1,824.4 million (tax authority, economic year). The 39,909 figure circulated as the 2023 NHR stock is the universe checked for tax debts; the stock was 114,645. Foreign nationals are 89.3% of IFICI registrants but Portuguese nationals are 5.9%, and the 4.8-point difference is unexplained. The Italian flat-tax figure of €300,000 is reported as enacted by one source and as a draft by another. Portaria 52-A/2025/1 is dated 25 February 2025 by the tax authority and by another date in the OCC guide; we use the authority's.
Failed claims: Lei 31-A/2024 as the source law (our own research brief), NHR 2.0 open to everyone, pensions exempt, a flat 20% on all income, first approvals in March 2026, approval in 30 to 90 days. Derived: the 136:1 ratio, the 0.73% share, the 652 and 147 registration increments, the 55.8% ratio of users to 2024 registrants, the 63.9% share of IRS expenditure, the 2026 filing deadline of 15 January 2027. Self-reported: the law-firm claim of more than 100 approvals. Our reading, not an authority statement: the treatment of foreign pensions and of remote workers. This is not legal or tax advice.
Frequently asked questions
What is IFICI, and is it the same as NHR 2.0?
IFICI is the Incentivo Fiscal à Investigação Científica e Inovação, created by Lei 82/2023 as article 58-A of the Estatuto dos Benefícios Fiscais. "NHR 2.0" is a trade nickname. It keeps NHR's 20% rate and ten years but limits eligibility to listed activities.
Who qualifies for IFICI?
A person who becomes Portuguese tax resident, was not resident in the previous five years, has not used NHR, IFICI or the Programa Regressar, and works in one of the listed routes: teaching and research, certified startups, qualified jobs at firms with investment contracts or export profiles, or highly qualified professions in listed industries (Portaria 352/2024/1).
What is the IFICI tax rate?
20% on net category A and B income of Portuguese source from the qualifying activity, for ten consecutive years (article 58-A EBF). Other Portuguese income follows the general IRS rules.
Is foreign income tax-free under IFICI?
In general it is exempt, with an exception for category H, which is pensions. Income paid from entities in listed more favourable tax regimes is taxed at 35% (Autoridade Tributária FAQ and Ofício-Circulado 20276/2025).
Can retirees or pensioners get IFICI?
No. Retirement is not a listed activity, and foreign pensions fall under the category H exception. Our reading is that a foreign pension is taxed under the ordinary IRS rules.
Do digital nomads and remote workers qualify?
Not as such. The law does not name remote work, and the 20% rate applies only to Portuguese-source income from a listed activity. A remote worker qualifies only by doing a listed role for a qualifying Portuguese entity. This is our reading; the tax authority has no statement on digital nomads.
Is NHR still available in 2026?
Not for new entrants. NHR closed on 1 January 2024, with a transitional route for people resident by 31 December 2024 who filed by 31 March 2025. Existing holders keep it for their ten years, and the IGF puts the end of the transitional regime at 31 December 2033.
How many people have registered for IFICI?
The Tribunal de Contas counts 946 registered taxpayers in May 2026, up from 147 in 2024 and 799 in 2025. It counts registrations. Only 82 taxpayers showed a benefit in the 2025 accounts, and no figure for approvals or refusals has been published.
How and by when do I apply for IFICI?
File on the Portal das Finanças by 15 January of the year after you become resident. Late filing gives the benefit only for the remaining years. The certifying entity or employer confirms the facts by 15 March, and the authority shows the status by 31 March.