HVAA List Portugal: Who Qualifies for NHR / IFICI (2026)

The 20% flat tax rate under NHR (legacy) 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.

IFICI (the 2024+ replacement) does not use Portaria 230/2019. It has its own, separately enacted list of highly qualified professions in Anexo I of Portaria 352/2024/1 - fewer codes, a higher qualification floor, and it governs only one of the six routes into the regime. This guide is the full NHR list, with examples for each code and a flag showing which codes also appear on the IFICI list. 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, for NHR: 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. IFICI inverts this - there, the employer’s status is what decides, and the same code 25 gets you nothing at an employer that doesn’t fit one of the qualifying categories.

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. IFICI sets a higher bar - a doctorate (EQF/ISCED level 8), or a degree (level 6) plus three years of documented professional experience. Experience alone is not enough there.

The full list (2026)

Activities grouped by category. The “IFICI” column flags which of these codes also appear on the separate IFICI list in Portaria 352/2024/1 - if it’s ”-”, the activity is NHR-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. Its list of highly qualified professions lives in Anexo I of Portaria 352/2024/1 and is, in full:

• 112 - Directors-general and executive managers of companies
• 12 / 13 - Directors of administrative, commercial, production and specialised services (excluding 1349)
• 21 - Specialists in physical sciences, mathematics, engineering (excluding 216)
• 2163.1 - Industrial and equipment product designers
• 221 - Medical doctors
• 231 - University and higher-education teachers
• 25 - ICT specialists

Seven of the seventeen NHR codes carried over. Notably dropped from IFICI: hospitality and commerce directors (14), dentists (2261), authors, journalists and linguists (264), creative and performing artists (265), mid-level science and engineering technicians (31), ICT technicians (35), and the skilled trades (61, 62, 7, 8). Doctors and company directors, by contrast, did carry over.

One further catch: this list only governs the “highly qualified professions” route, which requires the employer to be claiming RFAI or to be an exporting industrial/services company with a CAE on the Portaria’s Anexo II. The other routes into IFICI - higher-education teaching and scientific research, contractual investment-benefit jobs, AICEP/IAPMEI-recognised entities, SIFIDE R&D personnel, and certified startups - don’t run off CPP codes at all.

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:

• A one-off registration (pedido de inscrição) by 15 January of the year after you become resident - see the step-by-step IFICI Portugal application guide. You only re-register if the competent body or the employing company changes
• Documentation proving the qualifying activity (employment contract, role description, research outputs)
• Then an annual claim on Anexo L, plus an annual confirmation from your employer on the Portal by 15 March

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 - the NHR HVAA list
• Portaria n.º 352/2024/1 - Diário da República - the separate IFICI list of highly qualified professions
• Portal das Finanças - RNH FAQ