What's Included
You receive a defined-scope IFICI execution package designed to move from eligibility clearance to a defendable submission.
Application readiness check: verification that required eligibility inputs and supporting records are complete before submission work begins.
IFICI documentation pack: assembly of the submission file with supporting evidence and structure for authority review
Submission support and evidence capture: support through filing actions, with submission records kept.
Post-submission guidance: response-pathway support if clarification is requested by authorities.
Scope boundaries and timeline: defined-scope framing confirmed in writing before execution.
This structure gives the application pack a strong evidential foundation, reduces rework, and keeps the work documented.
What's Not Included
This service does not include
Initial IFICI eligibility assessment where no prior planning exists
Annual tax return preparation or filing execution.
Immigration legal filing or legal representation.
Assured regime approval outcomes.
Litigation or tax-court representation.
Ongoing unlimited advisory retainer.
Process & Timeline
Typical project execution is 2-6 weeks; external processing timelines can vary
Eligibility Basis Confirmation
We confirm your prior eligibility assessment and identify any documentation gaps.
Documentation Assembly
We build the IFICI pack and align supporting records to the documented position.
Submission Support and Evidence Capture
Support through filing actions with traceable submission records.
Post-Submission Guidance
Response-pathway support if clarification is requested by authorities.
- Final defined scope is confirmed before execution begins.
- Eligibility basis already documented.
- Completeness and quality of supporting records.
- Number of authority interactions or clarifications required.
- Complexity of the underlying cross-border profile.
Founder & Approach
We work the IFICI application in order: eligibility evidence first, then submission
In practice, we run each engagement to a clear sequence. We agree what is in scope, write down our assumptions, and note how anything outside that scope is handled before work starts. Clients know what they will receive because the scope is set first and the work follows it. That keeps your other advisors working from the same written facts, so the filings that follow do not contradict each other.
Quality control is built into each stage. We gather the facts first, state our assumptions plainly, and confirm the key decisions with you before any filing begins. When third parties are involved, we issue handoff-ready notes so each party works from the same baseline. This prevents the common pattern where one advisor optimizes for local filing convenience while creating unresolved exposure elsewhere. We also preserve an audit trail of key choices, so if facts change later, updates can be scoped quickly without rebuilding the full engagement from scratch.
Commercially, this model also protects clients from hidden escalation. The baseline scope is visible up front, exclusions are explicit, and any expansion is approved before work changes. With scope kept clear at each step, the engagement stays defensible, timelines stay realistic, and handoffs remain usable for filing and compliance teams
Primary Sources
These official sources are the starting point for checking current rules before applying them to a client fact pattern.
Frequently Asked Questions
Do I Need a Tax Position Review Before the IFICI Application?
Not always. If eligibility is already clear from your role and employer, we can start the application directly. When the facts are mixed, the review settles eligibility first so the application is filed once, correctly.
What Happens If at Asks for Clarification After Filing?
AT questions usually concern the activity code or the employer confirmation. Because the application pack documents both up front, replies are typically short. We prepare them with you before anything is submitted.
My Employer Has Never Registered an IFICI Employee. Is That a Problem?
No. Most have not. The application pack includes the employer confirmation in a sign-ready format, so HR reviews and signs rather than drafts.
What Is IFICI, and How Is It Different from the Old NHR Regime?
IFICI, the tax incentive for scientific research and innovation, is the regime under EBF art 58-A that replaced the NHR after it closed to new arrivals on 1 January 2024. It keeps the headline 20% flat rate on qualifying Portuguese employment and self-employment income for ten years, but eligibility is narrower: the income has to come from a defined activity rather than from simply arriving with a high-value profession, and foreign pensions are taxed under the normal rules rather than the favourable treatment the NHR gave them. If you registered for NHR before the cut-off, that status continues on its own terms.
Who Qualifies for IFICI?
Two gates apply. First, you must not have been a Portuguese tax resident in any of the five years before the year you become resident, and you must not have held NHR, the Return Programme under CIRS art 12-A, or IFICI before. Second, your income has to come from a qualifying activity under EBF art 58-A: higher-education teaching and scientific research, research and development personnel under SIFIDE, qualified roles in certified startups, jobs in companies recognised for productive investment, or a highly qualified profession on the Portaria 352/2024/1 lists. Confirming which path fits, if any, is what a Tax Position Review settles first.
How Does the 20% Rate Work, and When Do the Ten Years Start?
Qualifying Category A employment and Category B self-employment income from the eligible activity is taxed at a flat 20%, instead of the progressive IRS scale. The benefit runs for ten consecutive years, and the clock starts in the year you become a Portuguese tax resident, not the year you file the IFICI registration. The ten years are non-renewable, and the 20% applies only to income from the qualifying activity; your other Portuguese income is taxed under the normal rules. Each year within the ten, you have to stay resident and keep earning income from an eligible activity.
Does IFICI Exempt My Foreign Income from Portuguese Tax?
For most foreign-source income in the qualifying categories, yes: the exemption runs through CIRS art 81 n.º 4, which is the international side of the regime. Two limits matter. Foreign pension income (Category H) is not exempt, which is the main change from the old NHR. Income paid by entities domiciled in a blacklisted jurisdiction is also outside the exemption, under CIRS art 81 n.º 5. So someone with foreign dividends, interest, or qualifying employment abroad may benefit, while a retiree living on a foreign pension generally does not. The exact treatment turns on the income category and its source, which we map before relying on it.
What Is the Registration Deadline, and Is It Strict?
Registration is filed by 15 January of the year following the year you become tax resident. For someone who becomes resident in 2026, that means by 15 January 2027. The deadline matters: registering after it can put the benefit for that first qualifying year at risk. Because the application also depends on confirmation from the competent body for your path and from AT, the working timeline is shorter than the date alone suggests, so the pack is usually assembled well before January.
Which Authority Do I Register My IFICI Application With?
It depends on your eligibility path, because Portaria 352/2024/1 registers each path with a specific body. Higher-education teaching and scientific research go through the FCT; qualified jobs under contractual productive-investment benefits through AICEP; highly qualified professions on the Anexo I list through AT itself; qualified jobs in activities that AICEP or IAPMEI recognise as relevant to the national economy through AICEP or IAPMEI; research and development personnel whose costs qualify under SIFIDE through the ANI; and roles in certified startups through Startup Portugal. Identifying the correct body and the evidence it expects is part of the application readiness check, because the path sets both the route and the documents.
