About Taxbordr: founder-led IFICI eligibility advisory
Taxbordr is a Portugal tax advisory firm founded by Telmo Ramos, Ordem dos Economistas Cédula nº 16379, formerly KPMG Luxembourg and EY Lisbon. We map activities against the IFICI seven-paths framework before any application is filed. The deliverable is a Position Memo identifying the qualifying path, the supporting documents required, and a defendable application file. CAE classification is a frequent stumbling block; we run it carefully.
The seven eligibility paths in detail
Path 1: Innovative startup roles. Roles in companies certified as innovative startups under Lei 21/2023 (Estatuto da Startup e da Scaleup) plus Portaria 401/2023 (certification procedure). The startup must be certified by IAPMEI / Startup Portugal. The role must be Cat A employment or Cat B services. Founders typically qualify if the startup is certified.
Path 2: RFAI-eligible roles. Roles in companies benefiting from RFAI under CFI arts 22-26. RFAI ("Regime Fiscal de Apoio ao Investimento") is a productive-investment incentive available to qualifying CAE-classified manufacturing and service activities. The eligible-applications scope is set by CFI art 37 ("aplicações relevantes") and is central to the IFICI RFAI-path check.
Path 3: Highly qualified professions (Anexo I). Professions listed in Portaria 352/2024/1 Anexo I, exercised through Cat A or Cat B income from a qualifying CAE-classified activity. Anexo I includes information-technology architects, data-science roles, biotech-research roles, qualified engineers, and certain medical specialties. The list is closed; activities outside the list do not qualify under Path 3.
Path 4: AICEP / IAPMEI-recognised investment. Roles in projects with AICEP (Agência para o Investimento e Comércio Externo de Portugal) or IAPMEI (Agência para a Competitividade e Inovação) recognition for productive investment in Portugal. Recognition is project-specific and requires AICEP / IAPMEI sign-off on the investment plan.
Path 5: R&D personnel under SIFIDE. R&D-classified personnel in projects benefiting from SIFIDE II (Sistema de Incentivos Fiscais à Investigação Científica e ao Desenvolvimento Empresarial) under CFI arts 35-42. The R&D classification follows the Frascati Manual definitions, with Portuguese transposition through CFI.
Path 6: University teaching and research. Cat A income from public or private higher-education institutions under Lei 73/2014, or Cat A / Cat B income from research entities classified by FCT (Fundação para a Ciência e a Tecnologia).
Path 7: Madeira and Azores qualifying activities. Roles in companies operating in the Madeira or Azores autonomous regions with activity in the qualifying CAE list. The autonomous regions have specific activity scopes under their regional incentive frameworks.
Qualifying CAE codes (Rev 3)
Portaria 352/2024/1 Anexo II lists the qualifying CAE codes. CAE Rev 3 (Classificação Portuguesa das Atividades Económicas, Revisão 3) remains the IFICI-canonical classification despite the transition to Rev 4 under DL 9/2025 of 21 January 2025. The qualifying scope spans:
Section A: Agriculture, forestry, and fishing (selected sub-classes for high-value-added activities).
Section B: Mining and quarrying (selected sub-classes for strategic minerals).
Section C: Manufacturing, with broad coverage of high-value-added manufacturing including pharmaceuticals (CAE 21), computers and electronics (CAE 26), electrical equipment (CAE 27), machinery (CAE 28), motor vehicles (CAE 29), other transport equipment (CAE 30).
Section J: Information and communication, including IT services (CAE 62), data and computing (CAE 63).
Section M: Professional, scientific, and technical activities, including head offices and management consultancy (CAE 70), architecture and engineering (CAE 71), scientific research and development (CAE 72), advertising and market research (CAE 73), other professional, scientific, and technical activities (CAE 74).
Section R: Arts, entertainment, and recreation (selected creative-industry sub-classes).
Section P: Education, including higher education (CAE 854) and research-classified education entities.
Section Q: Human health and social work (selected sub-classes for medical research and high-specialty care).
The Anexo II list is the authoritative source. We map each activity against the published list before filing.
Highly qualified professions (Anexo I)
Anexo I of Portaria 352/2024/1 lists the highly qualified professions that qualify under Path 3:
Information-technology architects, software architects, system architects.
Data scientists, data engineers, AI / machine-learning specialists.
Cybersecurity specialists, penetration testers, security architects.
Biotechnology and life-sciences researchers.
Pharmaceutical research and clinical-research specialists.
Materials-science researchers, nanotechnology specialists.
Renewable-energy engineers, environmental engineers.
Chartered engineers in selected disciplines (mechanical, electrical, civil, naval, aerospace).
Medical specialists (surgical, oncology, neurology, cardiology, others as listed).
Certain creative-industry roles (architects, designers in cultural production).
The Anexo I list is closed. The profession must be held in a Cat A or Cat B context with a qualifying CAE-classified employer or activity.
CAE Rev 3 vs Rev 4: classification continuity
DL 9/2025 of 21 January 2025 introduced CAE Rev 4 to align Portugal with NACE Rev 2.1. The transition runs through 2026. For IFICI purposes, Rev 3 remains the canonical classification because Portaria 352/2024/1 Anexo II is published in Rev 3 codes. AT and IAPMEI accept Rev 3 for IFICI applications during the transition. We map cases in both Rev 3 and Rev 4 to handle both the IFICI application and any Rev 4 obligations on Cat B registration.
Application file: what to submit
The IFICI application file submitted to AT by 15 January of the year after residency starts comprises:
Identification: NIF, residency proof, registration number with Segurança Social.
Path selection: indicate which of the seven paths is being claimed.
Path-specific evidence:
Path 1: Startup certification from IAPMEI.
Path 2: RFAI eligibility statement, employer-side documentation.
Path 3: Employment contract specifying the Anexo I profession, employer's CAE classification, role description, qualification documentation.
Path 4: AICEP / IAPMEI recognition document for the investment project.
Path 5: SIFIDE-classified R&D project documentation, role description.
Path 6: University / research-entity employment contract.
Path 7: Regional-incentive documentation for the Madeira / Azores activity.
Anexo L on Modelo 3 for the year the regime applies.
Deadlines and timing
Standard deadline: 15 January of the year after Portuguese tax residency starts.
2024 first-year deadline: was 15 January 2025, extended to 31 March 2025 by Despacho 24/2025-XXIV.
2025 first-year deadline: 15 January 2026.
2026 first-year deadline: 15 January 2027.
Anexo L election on Modelo 3: by 30 June of the year after the income year (e.g. 30 June 2026 for the 2025 income year).
Common eligibility-mapping mistakes
First, assuming a tech role is automatically Path 3. Path 3 requires a profession listed in Anexo I plus a qualifying CAE classification. A "developer" not listed in Anexo I needs another path or another classification. Second, treating a foreign certification as automatic. Path 3 evidence is profession-based; the employer's CAE classification and role description are the controlling documents. Third, ignoring the difference between RFAI scope (eligible activities) and SIFIDE scope (R&D personnel). Path 2 and Path 5 are different mechanisms with different evidence. Fourth, ignoring the foreign-employer scenario. A Portuguese-resident worker for a foreign employer must establish an employer-side or self-employment-side path, not assume the foreign employer's CAE substitutes.
What this guide is not
This guide is general guidance, not advice on your specific situation. Each path has technical evidence requirements that depend on facts. For application support, see the IFICI Portugal application service.
Frequently Asked Questions
What is the IFICI rate?
20 percent flat on qualifying Cat A and Cat B Portuguese-source income, with foreign-source Cat A/B/E/F/G exempt under CIRS art 81 n.º 4. Applies for 10 consecutive years from the first year of qualification.
Where are the qualifying CAE codes published?
Portaria 352/2024/1 Anexo II, published 23 December 2024 in Diário da República. CAE Rev 3 remains canonical despite the Rev 4 transition under DL 9/2025.
Where is the highly qualified professions list?
Portaria 352/2024/1 Anexo I. The list covers IT architects, data scientists, biotechnology researchers, qualified engineers, certain medical specialties, and other defined professions. The list is closed; professions outside it do not qualify under Path 3.
What is the Portugal IFICI deadline?
The standard application deadline is 15 January of the year after residency starts. For 2025 first-year residents, the deadline is 15 January 2026. The Anexo L election on Modelo 3 is due by 30 June of the year after the income year.
Does IFICI use CAE Rev 3 or Rev 4?
Rev 3 for IFICI purposes. Portaria 352/2024/1 Anexo II is published in Rev 3 codes. DL 9/2025 introduced Rev 4 from 21 January 2025, but AT and IAPMEI accept Rev 3 for IFICI applications during the transition.
Can a software developer qualify for IFICI Path 3?
Only if the role description maps to an Anexo I profession (e.g. software architect, data scientist, AI specialist) and the employer has a qualifying CAE classification. A generic "developer" title without Anexo I mapping does not qualify under Path 3 alone, but may qualify through Path 1 (certified startup) or Path 4 (AICEP / IAPMEI project).
Was the 2024 first-year deadline extended?
Yes. Despacho 24/2025-XXIV extended the 2024-residency-year IFICI application deadline from 15 March 2025 to 31 March 2025.