What is TISRI? Understanding Portugal's NHR 2.0 Tax Regime
Portugal has introduced a new tax regime designed to attract highly qualified professionals, researchers, and innovators. Officially called the Tax Incentive for Scientific Research and Innovation (TISRI), or Incentivo Fiscal à Investigação Científica e Inovação (IFICI) in Portuguese, this regime is widely known as NHR 2.0 because it replaced the previous Non-Habitual Resident (NHR) tax regime.
If you’re a highly skilled professional considering Portugal, or you’ve recently moved here, understanding TISRI could save you a significant amount in taxes over the next decade.
What Happened to the Original NHR?
The original Non-Habitual Resident (NHR) tax regime officially ended for new applicants in 2024 (though transitional rules applied for some existing beneficiaries). It was replaced by TISRI, a much more targeted incentive focused on attracting specific types of talent rather than offering blanket benefits.
Key Difference from Old NHR
The most significant difference:
- Old NHR: Broad eligibility; attracted professionals across many fields plus foreign pensioners
- TISRI (NHR 2.0): Highly selective; focuses exclusively on scientific research, innovation, and high-value-added professions in specific sectors
The new regime is designed to be more strategic, targeting the exact types of professionals Portugal wants to attract for economic development.
What Are the TISRI Tax Benefits?
TISRI offers substantial tax advantages over a 10-year period. Here’s what you get:
1. Flat 20% Income Tax Rate
Portuguese-sourced income from qualifying activities is taxed at a flat rate of 20%, instead of Portugal’s standard progressive income tax rates (which can reach up to 53%).
This applies to:
- Employment income from qualifying professions
- Self-employment income from qualifying activities
Example: If you earn €60,000 as a qualifying professional in Portugal, your Portuguese income tax would be €12,000 (20%), instead of potentially €25,000+ under standard progressive rates.
2. Foreign-Sourced Income Exemption
Most foreign-sourced income is exempt from Portuguese taxation under TISRI:
- Employment and self-employment income earned abroad
- Dividends from foreign companies
- Interest from foreign bank accounts
- Rental income from foreign properties
- Capital gains from foreign assets (real estate, securities, cryptocurrency)
Important: While exempt, foreign income must still be reported to Portuguese tax authorities for the purpose of calculating the tax rate on any remaining taxable income (known as “exemption with progression”).
3. Critical Exclusion: Pensions
Unlike the old NHR regime, foreign-sourced pensions are NOT exempt under TISRI. Foreign pensions will be taxed in Portugal at standard progressive rates.
This is a major policy shift—the Portuguese government explicitly excluded retirees from the new incentive to focus on attracting working professionals.
4. Duration: 10 Years
The tax benefits apply for 10 consecutive years from the date you become a Portuguese tax resident, as long as you continue to meet the qualifying criteria.
Eligibility Criteria: Who Qualifies?
TISRI has strict requirements. To qualify, you must meet all of the following conditions:
1. New Tax Resident (from 2024 onwards)
You must become a Portuguese tax resident starting in 2024 or later. Those who became residents before 2024 are not eligible for TISRI (though some may still qualify under old NHR transitional rules).
2. Non-Resident in Previous 5 Years
You must not have been a tax resident in Portugal in the five years immediately preceding the year you become a resident.
Example: If you become a Portuguese tax resident in 2025, you cannot have been a Portuguese tax resident at any point from 2020-2024.
3. No Previous Benefit from NHR or Similar Regime
You must not have previously benefited from:
- The old NHR (Non-Habitual Resident) regime
- The “ex-resident” tax incentive
This is a one-time opportunity. If you already used the old NHR, you cannot also claim TISRI.
4. Engage in a Qualifying Activity
This is the most critical requirement: you must earn income from one of the specifically defined highly qualified activities or professions in Portugal.
Qualifying Activities and Professions
TISRI is designed for specific high-value sectors. Here are the main qualifying categories:
1. Higher Education Teaching and Scientific Research
Activities related to:
- University-level teaching positions
- Academic research
- Scientific investigation
- Research and development (R&D) in universities or research institutions
Who this covers: University professors, research scientists, PhD researchers
2. Qualified Positions in Productive Investment Projects
Jobs in companies that have obtained contractual benefits for productive investment from government entities like AICEP (Portuguese Agency for Investment and Foreign Trade) or IAPMEI (Agency for Competitiveness and Innovation).
These are typically strategic investment projects that the Portuguese government has specifically approved and incentivized.
Who this covers: Executives, managers, and technical specialists in approved investment projects
3. Highly Qualified Professions in Export-Oriented Companies
Highly qualified jobs in:
- Industrial companies that export at least 50% of their turnover
- Service companies that export at least 50% of their turnover
- Companies with eligible private investments certified by relevant authorities
Who this covers: Engineers, data scientists, product managers, software architects, business development specialists in qualifying export-focused companies
4. Certified Startup Employees
Positions in entities officially certified as Startups under Portuguese law.
Portugal has an official startup certification program. Companies certified under this program can hire foreign talent who qualify for TISRI benefits.
Who this covers: Developers, designers, technical leads, and other professionals working in certified Portuguese startups
What Does “Highly Qualified” Mean?
While not always explicitly defined, “highly qualified” typically means:
- Advanced education: Bachelor’s degree or higher (Master’s, PhD often preferred)
- Specialized expertise: Technical, scientific, or professional skills in high-demand areas
- Strategic roles: Positions that contribute significantly to innovation, R&D, or export growth
Common qualifying fields include:
- Software engineering and data science
- Biotechnology and life sciences
- Engineering (mechanical, electrical, aerospace, etc.)
- Advanced manufacturing and industrial R&D
- Financial technology (FinTech)
- Artificial intelligence and machine learning
- Clean energy and sustainability technology
How to Apply for TISRI
The application process is time-sensitive and requires coordination with multiple entities.
Step 1: Establish Tax Residency in Portugal
First, you must actually become a Portuguese tax resident. Generally, this means:
- Spending more than 183 days in Portugal during a calendar year, OR
- Having your primary residence in Portugal on December 31st of the tax year
Register your residence with local authorities and obtain your NIF (tax identification number).
Step 2: Confirm Your Activity Qualifies
Before applying, ensure:
- Your employer or activity meets the qualifying criteria
- You have documentation proving the activity is eligible (employer certificates, startup certification, university contract, etc.)
Step 3: Submit Your Application by January 15th
Critical Deadline: The application for TISRI status must be submitted by January 15th of the year following the one in which you became a tax resident.
Example:
- You become a Portuguese tax resident in 2025
- Application deadline: January 15, 2026
Do NOT miss this deadline. Late applications are generally not accepted.
Step 4: Obtain Required Certifications
Depending on your qualifying activity, you may need validation or certification from:
- Foundation for Science and Technology (FCT): For research and scientific activities
- AICEP (Agency for Investment and Foreign Trade): For productive investment projects
- IAPMEI (Agency for Competitiveness and Innovation): For SME investment projects and startups
- Startup Portugal: For certified startup status
- Your employer: For employment-related applications
Your employer or institution will often help coordinate these certifications.
Step 5: Submit Through Portal das Finanças
File your application electronically through the Portal das Finanças (Portuguese Tax Authority website):
- Log in with your NIF credentials
- Navigate to TISRI application section
- Upload all required documentation
- Submit the application
You should receive confirmation of your application status within several weeks.
Important Limitations and Considerations
1. No Guaranteed Approval
Unlike the old NHR, which was relatively easy to obtain, TISRI applications are scrutinized. You must genuinely meet the strict qualifying criteria.
2. Ongoing Compliance
To maintain TISRI status, you must:
- Continue to engage in qualifying activities
- Remain a Portuguese tax resident
- Report all income (including exempt foreign income) annually
If you change jobs to a non-qualifying activity, you may lose TISRI benefits for that year.
3. Exemption with Progression
Even though foreign income is exempt, it’s used to calculate your tax bracket for Portuguese-sourced income. This is called “exemption with progression.”
Example:
- Portuguese income: €40,000 (taxed at 20% flat under TISRI)
- Foreign dividend income: €20,000 (exempt, but reported)
- The €20,000 may still affect your marginal rate for other income or social security calculations
4. Local vs. Foreign Income Classification
Determining whether income is “Portuguese-sourced” or “foreign-sourced” can be complex:
- Portuguese employment: Always Portuguese-sourced
- Remote work for foreign company while in Portugal: Potentially Portuguese-sourced
- Freelance work performed in Portugal for foreign clients: May be Portuguese-sourced
Consult a tax advisor to properly classify your income streams.
5. Impact on Double Taxation Treaties
Portugal has tax treaties with many countries. TISRI’s exemptions may interact with these treaties in complex ways, especially regarding:
- Pension taxation
- Dividends and interest
- Capital gains
Work with a cross-border tax specialist if you have income from multiple countries.
TISRI vs. Old NHR: Quick Comparison
| Feature | Old NHR | TISRI (NHR 2.0) |
|---|---|---|
| Eligibility | Broad (many professions + retirees) | Narrow (research, innovation, high-value sectors) |
| Portuguese Income Tax | Varies by profession (often 20%) | Flat 20% for qualifying activities |
| Foreign Income | Generally exempt | Generally exempt (but not pensions) |
| Foreign Pensions | Taxed at 10% (or exempt if taxable elsewhere) | Taxed at standard progressive rates |
| Application Period | Until 2023 (closed for new in 2024) | 2024 onwards |
| Target Audience | General expat appeal | Highly qualified professionals & researchers |
Who Benefits Most from TISRI?
Ideal Candidates
TISRI offers the greatest benefits to:
- Research scientists and academics moving to Portuguese universities or research institutions
- Software engineers and tech professionals joining certified Portuguese startups or export-focused tech companies
- Senior professionals in industrial or service companies with 50%+ export revenue
- Highly skilled expats relocating for strategic investment projects
Who Should Look Elsewhere
TISRI is not suitable for:
- Retirees: Foreign pensions are fully taxed; the old NHR was better for retirees
- General remote workers: Unless your remote work clearly qualifies as a high-value activity in an eligible sector
- Small-scale freelancers: Unless you’re conducting qualifying research or working with certified startups
- Previous NHR beneficiaries: You cannot claim TISRI if you already used old NHR
Practical Tips for Freelancers and Consultants
If you’re a freelancer or consultant considering TISRI:
1. Structure Your Work Carefully
To maximize your chances:
- Partner with certified startups or qualifying companies
- Focus on innovation-heavy projects (R&D, product development)
- Document the high-value nature of your work
2. Get Pre-Approval Guidance
Before relocating, consult with:
- A Portuguese tax advisor familiar with TISRI
- The relevant certification authority (IAPMEI, AICEP, etc.)
Confirm your activity will qualify before you commit to moving.
3. Maintain Detailed Records
Keep thorough documentation of:
- Your qualifying activities
- Client contracts showing high-value work
- Export revenue if applicable (for company clients)
- Any certifications or validations
4. Plan Your Residency Timing
Since the application deadline is January 15th of the year following your residency, strategic timing matters:
- Become resident early in the year: Gives you more time to prepare the application
- Avoid late-year residency: You’ll have limited time to gather documentation before the January 15th deadline
Common Questions
Can I apply for TISRI if I’m already in Portugal?
Only if you became a tax resident in 2024 or later and meet the 5-year non-residency requirement. If you were already a resident before 2024, you cannot qualify for TISRI.
What if I change jobs during the 10-year period?
You must continue to engage in qualifying activities. If you switch to a non-qualifying job, you may lose TISRI benefits for the years you’re not in a qualifying position.
Can I be self-employed under TISRI?
Yes, as long as your self-employment activity is one of the qualifying high-value activities (research, innovation, working with certified startups or export-oriented companies).
Is there a minimum income requirement?
There’s no explicit minimum income stated in the law, but the nature of “highly qualified” activities generally implies professional-level compensation.
Can my family benefit from TISRI?
TISRI is an individual benefit. Your spouse or dependents would need to qualify independently based on their own activities. However, they may benefit indirectly if you structure family income through your qualifying activity.
Resources and Next Steps
Official Resources
- Portal das Finanças: https://www.portaldasfinancas.gov.pt – Apply for TISRI status
- IAPMEI: https://www.iapmei.pt – Information on startup certification and SME investment projects
- AICEP: https://www.aicep.pt – Productive investment project information
- Startup Portugal: https://www.startupportugal.com – Startup certification details
Get Professional Advice
TISRI is complex and has significant financial implications. Before applying:
- Hire a Portuguese tax advisor (contabilista or tax lawyer) with TISRI experience
- Consult with cross-border tax specialists if you have foreign income
- Coordinate with your employer to ensure proper documentation and certification
The cost of professional advice is minimal compared to the potential tax savings over 10 years.
Conclusion
TISRI (NHR 2.0) represents a major shift in Portugal’s strategy for attracting foreign talent. Instead of broad appeal, it targets highly skilled professionals in research, innovation, and export-oriented sectors.
Key takeaways:
- 20% flat tax on Portuguese-sourced income from qualifying activities
- Foreign income generally exempt (except pensions)
- Very strict eligibility: Must be in research, innovation, certified startups, or export-focused companies
- Application deadline: January 15th of the year following residency
- Not for retirees: Foreign pensions are fully taxed
- 10-year benefit period if you maintain qualifying status
If you’re a highly qualified professional in a strategic sector, TISRI can offer substantial tax savings. However, the regime’s narrow focus means many expats who would have qualified for old NHR will not qualify for TISRI.
The bottom line: TISRI is a powerful incentive for the right candidates, but it requires careful planning, proper documentation, and professional guidance to successfully obtain and maintain.
Considering freelancing or consulting in Portugal? Check out our guides on Trabalhador Independente vs ENI, understanding Faturas, and managing IRS payments.