The new TISRI or NHR 2.0
What is TISRI?
The Tax Incentive for Scientific Research and Innovation (TISRI or IFICI, in Portuguese) is a Portuguese tax regime that entered into force on January 1st, 2024 and replaced the Non-Habitual Resident (NHR) tax regime.
It is a regime that aims to attract highly qualified professionals to Portugal, particularly those involved in scientific research and technological innovation activities, by granting tax benefits in within Personal Income Tax (PIT).
What benefits does TISRI offer?
- PIT rate of 20% on income from dependent or independent work (category A and B) obtained in Portugal derived from any of the scientific research and technological innovation (CI&TI) activities specifically provided for in the law (instead of being subject to the progressive PIT rates and the additional solidarity surcharge, up to 53%; and
- PIT exemption on foreign source income, with the exception of pensions and income from tax havens. Labour income, passive investment income (e.g. interest and dividends), rental income and capital gains (e.g. from the sale of shares, crypto-assets, real estate, etc.) are covered by this exemption. The exemption is granted without the need to confirm the taxation rights laid down in double taxation treaties
Who is eligible for TISRI?
All natural persons who:
- Become tax resident in Portugal from 2024 onwards and have not been tax resident in Portugal for at least 5 years prior to the year in which they become resident; and
- Carry out in, Portuguese territory, one of the CI&TI activities specifically provided for in the law.
Which activities are covered and how to register in TISRI?
Activity developed | Entity responsible |
a. Teaching in higher education/scientific research or jobs or MOS in technology and innovation centres. | Foundation for Science and Technology |
b. Qualified jobs and MOS within the framework of contractual benefits for productive investment. | AICEP, E.P.E. |
c. Highly qualified professions for personnel with a PhD (or a bachelor’s degree and at least three years of professional experience) carried out in companies with relevant applications within the scope of the RFAI or industrial or service companies that export at least 50 per cent of their turnover.
List of highly qualified professions: · General and executive directors of companies; · Directors of administrative and commercial services; · Directors of production and specialised services (except directors of libraries, archives, museums, art galleries and national monuments, officers and other professionals in the security forces and services with command, direction or leadership functions or directors of other specialised services not specified); · Specialists in the physical sciences, mathematics, engineering and related techniques (except architects); · Industrial product or equipment designer; · Medical doctors; · University and college professors; · Specialists in information and communication technologies (ICT). List of industrial and service activities: · Extractive industries; · Manufacturing industries; · Information and communication activities · Research and development in the physical and natural sciences; · Higher education; or · Human health activities. | Tax and Customs Authority |
d. Other qualified jobs and MOS (with at least a post-secondary non-tertiary level of education), in entities carrying out economic activities recognised by AICEP, E. P. E., or IAPMEI, I. P. E., or by IAPMEI, I. P..
List of qualified job positions recognized by AICEP, E.P.E.: · General director and executive manager of companies (including administrators, managers, or general directors of companies); · Directors of administrative and commercial services; · Directors of production and specialized services. · Directors of hospitality, catering, trade, and other services; · Specialists in physical sciences, mathematics, engineering, and related techniques; · Medical doctors; · University and higher education professors; · Specialists in finance and accounting (excluding accountants, auditors, statutory auditors, and similar professions); · Specialists in information and communication technologies (ICT); · Film, theatre, television, and radio directors, producers, and stage managers; and · Mid-level technicians and professionals in science and engineering. List of activities recognized by AICEP, E.P.E. as relevant to the national economy: · Extractive industries; · Manufacturing industries; · Electricity, gas, steam, hot and cold water, and cold air supply; · Construction; · Accommodation, catering, and similar activities; · Information and communication activities; · Financial and insurance activities; · Consulting, scientific, technical, and similar activities; · Administrative and support service activities. · Education; and · Human health and social support activities – division 86 (excluding thermal activities and other unspecified human health activities). | IAPMEI, I.P. or AICEP, E.P.E. |
e. Research and development of personnel whose costs are eligible for SIFIDE II. | National Innovation Agency. S.A. |
f. Jobs and MOS in certified start-ups. | Startup Portugal |
g. Jobs or other activities carried out by tax residents of the Azores and Madeira. | Autonomous Regions of the Azores and Madeira |
Taxpayers who are eligible for the TISRI must apply to the responsible entity depending on the activity developed.
Along with the application for enrolment, the taxpayer must submit:
- Copy of the individual employment contract, when the activity carried out is a job;
- Up-to-date permanent commercial certificate, when the activity carried out is that of MGB;
- Copy of the scholarship contract, when the activity carried out is scientific research;
- Proof of applicable academic qualifications;
- Declaration issued by the competent authorities attesting to the fulfilment of the requirements relating to the activity carried out, in the case of the activities provided for in points b), c), d) and e) above; and
- Other documents that may be requested.
It is the responsibility of the company in which the activity is carried out to prove the requirements relating to the activities set out in point c), by confirming, by 15 March, in the respective reserved area of the Tax and Custom authority’s website, that the taxpayer meets the requirements set out in points i) or ii) of that point, as well as the exercise of the highly qualified profession by the same taxpayer.
What is the deadline for registration?
Eligible taxpayers can apply to join the TISRI until 15 January of the year following the year in which they become tax resident in Portugal (for example, if a person becomes tax resident during 2025, they will have until 15 January 2026 to apply to join the scheme).
It is important to note that, since the practical regulations for the scheme were only published at the end of December 2024, those who became tax residents during 2024 may exceptionally register until 15 March 2025.
How long do the benefits last?
The benefits of the regime apply for 10 consecutive years.
To continue benefiting from the regime, the taxpayer must continue to (i) be considered a tax resident in Portugal and (ii) carry out one of the eligible activities.
The activity carried out can change, however, and if there is a change in the entity with which the application for registration must be submitted or the company that must prove the requirements, the taxpayer must submit a new application for registration.
Final take-aways
Although the TISRI is applicable to a smaller universe of people (only those who carry out one of the CI&TI activities specifically provided for), the benefits it offers are more extensive than the NHR, since the exemption from PIT on foreign source income no longer depends on the fulfilment of the conditions provided for in the double taxation treaties (for example, capital gains realised from the sale of foreign shares did not, in most cases, benefit from the exemption provided for by the NHR because they could, as a rule, only be taxed by the state of residence, i.e. Portugal, and the condition of “being able” to be taxed at source was not met – under the TSIRI, such income will be directly exempt).
At Belim, we are available to help you confirm the application requirements, including the criteria for tax residency in Portugal and those relating to the CI&TI activities, as well as the procedure for registering and submitting annual tax returns, helping you to make the most of this tax regime.
Contact us for more information.
 | How can we help? | We are a law firm based in Portugal, specialising in Portuguese tax and customs law. |
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