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.