Can Golden Visa Applicants qualify for NHR 2.0 and receive tax benefits in Portugal?

Residencies & citizenships Portugal Golden Visa 🇵🇹
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Yes!

Golden Visa applicants who choose to use their Golden Visa to move to Portugal permanently become tax residents and are subject to taxation in Portugal on their worldwide income. Such GV applicants are eligible and can apply and obtain the new and lucrative NHR 2.0 status (also called IFICI or TISRI in English), granting benefits for a period of 10 years. The greatest benefit is an exemption from nearly all types of foreign-sourced income.

Golden Visa applicants who do not move to Portugal do not need NHR 2.0 because they are subject to tax in their country of residence and they do not need to pay tax in Portugal unless they earn money in Portugal.

So NHR 2.0 is mainly of interest to Golden Visa applicants who either have plans to move to Portugal or at least want to keep the option of moving to Portugal as a plan B.  

Who can qualify? Is it true that the criteria is very narrow?

The reality is that nearly anyone can qualify for TISRI. Unlike NHR, it requires a certain type of work connection to Portugal, but such a connection can be a company in a particular sector or a board position in a certified startup company, so if tax benefits are important for you, TISRI is achievable.

More specifically, setting up a company with a certain activity code or having a board position in a startup are the easiest routes to TISRI.  

Why should I think about TISRI when I apply for Golden Visa? Isn’t it only relevant for later when I decide to come to Portugal?

When you apply for a Golden Visa, you are making a very significant investment. It is a competitive market and the funds are very keen to compete on receiving your investment. Therefore, at the time of applying for Golden Visa, you are in a very strong position and have leverage to make requests to the funds in exchange for investing with them.

At FRESH, we developed a collaboration with funds that already enables the conditions for TISRI if and when you decide to come to Portugal as part of your investment. If you end up coming to Portugal, everything will already be in place for you to receive tax benefits.  

How can you apply for TISRI?

Contrary to previous publications, applications for TISRI will be done via the tax authority website as before. The tax authorities will be communicating directly with the relevant certification entities and approving the application.

The application form just became available today, March 4, 2025. The application deadline for 2025 has been extended to the end of March. For future years, the deadline is January 15 the year after becoming a tax resident.

If you have additional questions on this topic, feel free to post them below or reach out directly.

This is a companion discussion topic for the original entry at https://nomadgate.com/portugal/legal-questions/golden-visa-qualify-for-nhr-2-ifici
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Thank you for doing this Q&A @ZeevFisher!

A couple additional questions from me:

Is it necessary to apply for TISRI/IFICI in the first year after your arrival, or can you apply in a later year (say if you don’t hold a qualifying position upon arrival, but get one later)?

If you can apply later, I assume the 10-year countdown already starts ticking from when you move to Portugal, not when you apply?

Also, after having looked at the application form yesterday I noticed that both when selecting options C (export companies) and F (startups) there are questions about your educational and/or work credentials.

Do the requirement to having at a minimum a PhD or Bachelor’s degree plus three years work experience apply to any path, or just some? Specifically, does it apply when you’re a director or board member for a startup or export company (as opposed to e.g. working in an IT role)?

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For individuals who already invested in other funds / real estate, e.t.c - What are the realistic options to be eligible for NHR 2.0? Does it need additional investment into a startup and become a board member?

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Hi Joel,

Investment is actually not a criteria for NHR 2.0. What opens the best door is a board seat in a certified startup. If you can get yourself one based on your skills and CV alone, you don’t need to invest anything, but normally startups will expect something from you to give you a board seat and we are already seeing that a market will emerge (and we are facilitating) where you invest and get a board seat. The investment amount depends on your background, startup stage, chemistry with the founder etc. I’d say that 100K will get you a board seat easily. 50K will be tough.

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Hi Thomas,

Great questions.

First question - if you do not apply on time, you can still apply a year later, but you lose a year of benefits. The application will not be rejected for that reason as NHR applications have been rejected. This is probably them learning from their mistakes with NHR.

Second question - the export company route as well as the IAPMEI route which are pretty similar do require a specific activity of the company, a specific role within the company and at least a bachelor + 3 years of experience and it is fairly likely that these would be audited.

The startup route does not require anything beyond having a role (any role) within a certified startups or a board position. That is the main reason that we have a strong preference towards this route and feel that it would be the best. Also Startup Portugal is a very friendly entity compared to IAPMEI and Finances so they are a better regulator in this sense.

Indeed, the form gives the same fields for uploading supporting documents for all routes it seems, but the applications will have to be assessed based on the criteria in the law and the form is likely like this because it was created in a rush. It also crashes now for new applicants so it would probably be a few more days before it works smoothly.

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Erm… I usually rate Fresh Portugal’s advice quite highly, but…

Please tell me this isn’t just a scheme to sell bogus Board seats/Directorships to “qualify” for IFICI/NHR 2 tax advantages. The way you’re pitching this, it seems that if the extent of my Tech Industry expertise is watching cat videos on my phone but I’ve got 100K to splash on some random PT startup, then I can “easily” get a Board seat.

Also my understanding is you have to prove your eligibility for IFICI/NHR 2 every year of the 10 it’s good for. So if the random PT startup you found for me fails after a couple years (up to 90% of Tech startups fail), you promise to find another random PT startup for me to be a Board member of - even if my 100K investment evaporated with the previous startup?

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Is there any limit to the number of board seats a startup can have? I might have a startup idea of my own… :sweat_smile:

/s

But seriously, I assume there would be a bit more to it than that (see e.g. how the HQA program works). But I’ll let Zeev answer for himself.

Good question… I’d be interested in learning more about this, too.

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We could start up a startup that creates startups for the purposes of allowing people to qualify for NHR 2 :slight_smile:

Using AI, we could create hundreds per day, all related to AI BlahBlahBlah, with full business plans, websites, etc.

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Hi @PTbound

I’m glad that you normally rate our advice.

A primary reason that the previous NHR regime was cancelled was that there has been a sentiment that it’s “not fair” because “expats pay less than locals”. An extreme version of that was an annual report of the “spending” of the government in “NHR tax benefits”, a figure that “could have gone towards education, healthcare etc”.

This is of course not how economies work. People come for the tax benefits and in the absence of tax benefits, many people won’t come so tax benefits create a framework where expats pay less % but more $ and the net outcome is a major gain to the economy (or as the previous prime minister described it, “a goose that lays golden eggs”, before he had to divert attention due to corruption charges).

All that is to say that we have to be very careful with simplistic narratives.

Now moving to your comment - investors getting board seats is precisely how tech investment works in every market. There is nothing “bogus” about “selling board seats for money”. Board seats ARE sold for money in every tech economy and this is highly desirable and precisely what’s good about this scheme and NHR was missing. I struggle to think of a better deal that a country can make in exchange to tax benefit than money going into its tech startups.

Now obviously, if tax benefits are an incentive to invest (as they are in many markets, including the UK and the US), the market obviously needs to regulate it. If someone can add a lot of value to a startups by virtue of their connections, experience and gravitas, they may well be offered a board seat without any investment but if someone has , as you describe it, only watched cat videos for iPhones, than they would need to add more value through injection of capital.

Either way, the law has not placed an experience requirement on directors of startups and we follow the law for the benefit of our clients. If the government changes the law in the future, they will need to do it without retroactive effect and I seriously doubt they will change this.

Now, I understand that the cats on iPhone example is made to prove a point, but having been in tech most of my life, I can tell you that experienced board members can be great but also destructive for a company and people without tech experience can sometimes add a lot of value. For example, a friend of mine has a tech VC that brings sports stars and influencers to invest in startups and use their outreach to promote them. We just agreed an investment with a client with such an influencer profile. When I say that a market will emerge, part of what I mean is that very few people coming to Portugal are watching cat videos. Most of them have skills and talent that can be put into use and add value and the local industry is absolutely thrilled about putting those skills to work and that is what we intend to facilitate. But yes - some of those investors could end up being fairly passive. And that’s fine.

Finally, very good question on the qualification every year. You are absolutely right - startups can fail. We have a whole plan for this that would include investment through a fund which will in turn fund an accelerator. So yes we will be able to move people to different projects.

I am incredibly excited about this. Getting expats involved and properly integrating and supporting the real economy is my firm’s vision and the reason I’m staying in Portugal. I’m fed up with being blamed for house prices inflation and not integrating and I believe that this could be scheme that we have all been waiting for that finally connects all the dots and I believe that we should all approach this with optimism and see the opportunity. Going down the route of “oh, this is a scam meant to save the rich foreigners money” is just a destructive way to look at things and I don’t see it like this at all.

I have written about this before 2 months ago:

Peace!

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Love your answer! A lot of economies in the world thrive on Foreign direct investments. That’s a lot of freaking value added to their economies just by virtue of capital infusion. As with any vague frameworks, it’s susceptible to freeloaders though. Either way, my skepticism is more on the Portuguese government to renege.

So, do i understand it right? the board seat must be a paid position? So are we talking about a cost of 100k yearly? Because i’m assuming it involves a salary component paid to yourself (Board member), no?

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I don’t necessarily think it needs to be a paid position beyond paying the minimum social security contributions. But open to be corrected on this.

Totally, agree that it’s a lot of value added through capital infusion. Arguably a €100K investment in a startup can do much more for the Portuguese economy than buying a €280-500K property (as in the previous version of the Golden Visa program).

While @PTbound’s cat video comment was quite funny and also an important issue to address, I think that buying access to IFICI with a startup investment is far from abuse of the system. Like Zeev says, it’s the system functioning much better than under NHR 1.x.

The perhaps most “gaming the system” way of qualifying I can think of would be to set up your own company, become the director, pay the required minimum social security payments on your own behalf, sell a token amount of “consulting” to “clients” abroad to qualify as an export business, and then just coast along with that. The only real requirements would be to have a bachelor degree and a few years of work experience.

You’d have maybe a few thousand in expenses per year (accounting, social security), so definitely more accessible than going the startup board seat route. But at the end of the day you add very little value to the Portuguese economy, and don’t really interact with it either.

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Thanks for your detailed response @ZeevFisher

I’ve also been in Tech for over 30 years, and indeed know a few tech incubator/accelerator Founders. I have never heard them say anything like “What we really need here is more Board Members.” If you wanted to buy your way in, you’d need to be flashing $100 million at them not a measly $100 grand.

It’s easy to blow through $100k as a tech startup… on misguided ideas, poor management, or just blunders like badly configured Facebook campaigns or AWS auto-scaling.

And given the very high failure rate of tech startups, how do you keep this incubator/accelerator afloat to justify its growing multitude of Board Members? Will there be cash calls to recapitalize it? Or does this scheme only work if there’s a constant flow of new “Board Members” bringing money in?

I have to be honest, the optics of this don’t look great. I can already see the news headline: “Portuguese Tech Incubator’s Main Product is Board Members.”

If Portugal genuinely wants FDI in Tech/whatever that’s great. Start by fixing its horrifically broken ARI, where investors put hundreds of thousands into PT and then spend years waiting for any sign of approval. Where they can’t sue to protect their administrative rights because the court system is overwhelmed with such cases. Where even if they got approved they can’t renew their visas.

Tax breaks are nice. But what we really want is the GV that we already invested in - many years ago with only broken promises in return so far.

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According to the law, the position does not need to be paid and we don’t expect these positions to be paid.

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I agree but we also expect more scrutiny on the “set up your own company” route and suspect that if these will not be real active companies, they might be targeted, for exactly the reason you mentioned. Also IAPMEI is notorious for being slow and inefficent (would love to see it improve) and startup Portugal known to be a good actor.

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With respect, you may have 30 years in tech but clearly not a single day in tech in Portugal. I have been active in 3 tech ecosystems and can tell you that they are completely different from each other. I actually invested in multiple Portuguese startups (and have been offered board positions repeatedly which I just don’t have time to take), after investing in UK startups, have been mentoring them and have been talking to some of the people writing the laws, so I speak from a position of deep familiarity with the ecosystem.

Sure - there are unicorns in Portugal where 100K won’t get you anywhere but there is also a large number of early stage startups that are starving for cash. The average salary is 1,500 Euros a month. You can get a decent developer for 40-50K a year and a junior for 25K. 100K is a LOT of money in Portugal and there is almost no early stage capital (there is, weirdly, a lot of late stage capital due to another tax benefit).

In addition, there is severe lack of expertise and network with the US. For early stage startups in Portugal, 100K is A LOT and a board member with added value is a desirable thing. No-one intends to stock-pile companies with board members. There is no need. There are enough companies with enough real need for that cash. What you describe may be right in silicon valley, but the reality in Portugal is very different and Portugal knows that.

I do agree that it’s easy to burn 100K but that is yet another reason for bringing in more expertise. There are not enough existed founders coming back for another round.

In the worst case scenario that you describe, if Portugal will end up having companies with more board members that are burning through money of these expats, that is not such a terrible scenario at all. Burning money is also how you fail and learn and create better companies.

I completely disagree with you about the importance of tax benefits. For those coming to Portugal, tax benefits are critical and they will not and cannot come without them. It’s one of the best things Portugal has ever done. And by the way, UK investors get back up to 82% of money invested in early stage and they invest for tax benefits to a very significant extent. Other countries are doing similar things and it’s a very common way to promote industries.

Finally, I completely agree that what happened with Golden Visas for people like you, who don’t want or intend to move to Portugal is an absolute disgrace and it certainly should be fixed. This is a completely valid point but is a different point that’s unrelated to the one we have been discussing. I don’t know if you have been following the news but AIMA is at least making strong signs of improving and we have indeed seen some movement so really hoping that things will get better.

I think that from my perspective, I exhausted what I have to say about this. It’s fine to have different opinions.

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I actually do spend plenty of time in Portugal, and know that $100k goes much further there. But that doesn’t mean Tech startups fail much less frequently (as a percentage of total) in PT than the US. So this scheme’s constant need for new cash still exists.

Still not clear what happens if my 100k gets burned-off in Year 1 - am I still a startup Board Member for the next 9 years at no additional cost to me? If yes then to continue the scheme must rely on new investor cash + hoped-for profits + hoped-for IP sales, right?

Also if this really takes off, I’m not sure how you’re going to answer to the press why these startups have more Board Members than people actually working on the technology.

I see a LOT of PT GV promotion, and they always use tax benefits in their sales pitches. Now their pitches are full of “NHR lives on in a new form, it’s all wonderful.” But spend time on this forum and you’ll find that’s the bait - the switch is that the PT ARI (and court) system is totally broken. So good luck getting/renewing that GV you were promised when you were lured in with tax breaks. It will cost you a lot more (legal fees… perhaps another $100k to become a startup Board Member for NHR 2?), and take far longer than you ever thought possible.

As for “AIMA is at least making strong signs of improving and we have indeed seen some movement,” real-life reports from people on this forum indicate so far that’s just more empty promises from AIMA. And last week Leitão Amaro confirmed that GV/ARI investors are at the back of the queue, behind those already in PT and 220,000 CPLPs.

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