The regulatory framework for the Tax Incentive for Scientific Research and Innovation, the so-called “NHR 2.0 scheme”, was recently approved by Ordinance no. 352/2024/1, of 23 December 2024 (the “Ordinance”), with retroactive effects as of 1st January 2024.
In a nutshell, the NHR 2.0, approved by the State Budget for 2024, put forward a tax incentive regime allowing for the application of a 20% flat rate to employment and self-employment income, notably, when derived from highly qualified professions carried out at the service of companies acting in eligible sectors of activity, as well as an exemption for all employment, self-employment, investment, rental income and capital-gains from foreign sources. In any case, the scheme was still pending regulation, particularly as to (1) the application procedure, (2) the list of “highly qualified professions” and (3) the “eligible sectors of activity”.
According to the Ordinance:
1. The application shall be submitted until 15 January of the year following the change of residence to Portugal (except for individuals that changed residence in 2024, that may apply until 15 March 2025);
2. The following are deemed “highly qualified professions”, provided they meet minimum qualification requirements:
- 112 – General managers and executive managers of companies
- 12 – Directors/heads of administrative and commercial services
- 13 – Directors/heads of production and specialized services
- 21 – Specialists in the physical sciences, mathematics, engineering and related techniques
- 1 – Industrial product or equipment designer
- 221 – Medical Doctors
- 231 – University and higher education Professors
- 25 – Specialists in information and communication technologies (ICT)
3. The following are deemed “eligible sectors of activity”:
- Extractive industries
- Manufacturing industries
- Information and communication activities
- Research and development of physical and natural sciences
- Higher education
- Human health activities
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