Highly Qualified Activities (HVAA) Portugal - Who Qualifies for NHR / IFICI

The 20% flat tax rate under NHR (legacy) and IFICI (2024+ replacement) applies only to income from a specific list of high value-added activities (HVAA) defined in Portaria 230/2019. If your work doesn’t match a code on this list, your income falls back to standard progressive brackets - no 20% benefit.

This guide is the full list, with examples for each code and an explicit flag for which subset of activities also qualifies under IFICI (the narrower 2024+ regime). For a side-by-side of when each regime saves you most, see NHR vs IFICI vs Standard.

How the list works

Portaria 230/2019 ditched the older CAE-based system and switched to CPP codes (Classificação Portuguesa das Profissões) - the Portuguese profession classification. Each code refers to a specific kind of work, not the industry the company is in.

This means: what you do matters, not who you work for. A software engineer at a shipping company qualifies under code 25 (ICT specialist) the same as a software engineer at a tech startup. The work itself is what’s classified.

There’s also a fundamental qualification requirement on top of having the right CPP code:

The taxpayer must possess at least Level 4 of the European Qualifications Framework (EQF) — typically a high-school diploma or post-secondary technical qualification — OR demonstrate 5 years of professional experience in the field.

In practice this means: a degree, a vocational diploma, or 5+ years of demonstrable experience. Most professionals in the listed categories already meet this.

The full list (2026)

Activities grouped by category. The “IFICI” column flags which codes are also eligible under the narrower IFICI regime - if it’s ”-”, the activity is HVAA-only (NHR holders qualify; new IFICI applicants don’t).

What “ICT specialist” actually means

Code 25 (ICT) is by far the most-claimed HVAA category among expat professionals. AT has been more rigorous about this one in recent years. To genuinely qualify:

• Your work must be at a specialist level, not a junior or general role
• “Software developer” qualifies; “IT support” might fall under code 35 (technician) instead
• Self-taught developers without formal qualifications should claim under the “5 years experience” route

The risk: AT can audit and reclassify if they think your role is general administrative work that happens to use computers. Be ready to demonstrate technical depth - code samples, role description, projects.

What does NOT qualify

A few activities people often assume qualify but don’t:

• General lawyers and accountants under HVAA only when they’re at a directorial level (code 12 / 13) - junior legal/accounting staff don’t qualify
• Junior researchers without academic appointment - only code 231 applies to recognized university faculty
• General consultants without a specific technical specialty
• Real estate, hospitality staff (non-management) - only directors of these businesses qualify (code 14)
• General sales / marketing roles - unless at director level (code 12)

If your work doesn’t fit any code clearly, you don’t qualify. There’s no “creative interpretation” path that survives an AT audit.

IFICI - the narrower 2024+ regime

IFICI (Incentivo Fiscal à Investigação Científica e Inovação) replaced NHR for new applicants from 2024. It uses a narrower subset of the HVAA list, focused on:

• Scientific research and qualified innovation roles
• ICT specialists in research/innovation contexts
• Technical and intermediate-level professionals supporting R&D
• University and research-institution faculty

Notably excluded from IFICI even though they qualify for NHR: company directors (12, 13, 14), medical doctors (221, 2261), creative professionals (264, 265), and skilled trades (61, 62, 7, 8).

How to claim

For NHR (existing holders only):

• Claim already established at registration; just declare income from the qualifying activity each year on Anexo L of Modelo 3
• Use the CPP code on your invoices (recibos verdes) and on your annual declaration

For IFICI:

• Annual registration required at AT - see the step-by-step IFICI application guide
• Documentation proving the qualifying activity (employment contract, role description, research outputs)
• Approval is per-year - re-validated each tax year

Quick check by job title

Not sure which CPP code matches your work? The free NHR / IFICI eligibility checker takes a job title in English and returns the most likely matching activities, with separate flags for NHR vs IFICI eligibility.

Cross-check with the calculator

The TAXCLARA calculator has a qualifying activity share slider that appears when NHR or IFICI is selected. If only part of your income is from a qualifying activity (mixed work), set the slider to that fraction - the calculator applies the 20% flat rate only to that portion and uses standard progressive brackets for the rest.

For most expats with a single technical role (software engineer, doctor, university researcher), the share is 100%. For hybrid situations (consulting + teaching, mixed activities), it’s not.

Sources

• Portaria 230/2019 - Diário da República
• APCMC - Tabela atividades elevado valor acrescentado
• TPA Law - NHR Alterações da Tabela
• Portal das Finanças - RNH FAQ