After presenting the OE2024 proposal, the Minister of Finance confirmed that "there will no longer be a regime [NHR of universal and transversal application" from 2024 onwards. This means that all processes "whose processing takes place by the end of the year, are covered by the current law", he clarified.

But the Government wants to continue attracting qualified talent, through another regime. "The conditions for attracting investment relevant to the Portuguese economy remain intact", whether through the reduction of IRC for companies or through the IRS. "It will be maintained as a mechanism for capturing structuring investment", highlighted Fernando Medina, quoted by Dinheiro Vivo.

He was referring to the new tax incentive for scientific research and innovation included in OE2024, which aims to help companies capitalise. This new tax benefit was created along similar lines to the NHR, but is aimed at a specific audience. “A new tax incentive for scientific research and innovation (IFICI) is created, aimed at attracting and retaining highly qualified staff in the fields of scientific research, investment and business development”, reads the OE2024 proposal.

How will the new tax incentive for scientific research and innovation work?

From the outset, this tax incentive will be applied “to researchers and highly qualified workers who, having not been tax residents in the last 5 years in Portugal, have become residents”, according to the OE2024 proposal.

Afterwards, these workers must present income that falls into:

- Careers of higher education and scientific research teachers, including scientific employment in entities, structures and networks dedicated to the production, dissemination and transmission of knowledge, integrated into the national science and technology system;

- Qualified jobs within the scope of contractual benefits to productive investment;

- Research and development jobs, for workers with doctorates, within the scope of SIFIDE.

People who meet these requirements benefit from an IRS tax rate of 20% "on net income of categories A and B earned" within the scope of those activities "for a period of 10 consecutive years from the year of their registration as a resident in Portuguese territory".

The OE2024 proposal provides, on the other hand, that people who can benefit from this regime "and obtain, abroad, income from categories A [dependent work], B [independent work], E [capital], F [property] and G [capital gains or other asset increases], the exemption method applies, and must be included for the purposes of determining the rate to be applied to remaining income".

The requirements (having to reside at least 183 days per year in Portugal and not having been a resident in Portugal in the previous five years) and the benefits (paying a special rate of 20% IRS for 10 years) are essentially the rules of the regime non-habitual resident tax that is now revoked and that was accessible to a list of professions considered to have “high added value”, with a scientific, artistic or technical nature. This included professions such as doctors, architects, singers, musicians, actors, tax consultants, auditors, university professors, consultancy and computer programming workers or data processing professionals.