i. INTRODUCTION
Since around 2010, the Portuguese government implemented a tax regime with the purpose of attracting non-residents to transfer their residence to Portugal – the Non-Habitual Resident status. This regime had very broad conditions, which made it a huge success. This success determined its death, and the regime was revoked with effect to the end of 2023.
However, the same law that closed that regime opened a new one, with effect to 1 January 2024, replacing the Non-Habitual Resident regime, now with the specific aim of attracting highly qualified professionals to specific areas of activity, promoting the development of an economy geared towards innovation and digital transformation and increasing the competitiveness of Portuguese companies. To this end, Article 58-A was introduced into the Tax Benefits Statute (EBF).
Although the new regime had been implemented, it took quite a while until the conditions required for its effective implementation were made available, and it was only on 23 December 2024 that a Ministerial Order was published to regulate the new tax incentive scheme (IFICI) provided for in article 58-A. The regulations establish, among other things, the applicable registration procedures, the highly qualified professions, as well as the industrial and service activities that fall within the scope of this scheme.
Later, on February 13, 2025, a government department (IAPMEI) published another relevant list, now of the qualified jobs and the economic activities considered relevant to the national economy.
Finally, an Order published on 20 February 2025, approved the registration form for the scheme.
As we shall see, in contrast to the previous regime, this new one is based on strict conditions as to whom may benefit from it.
