Can you hold a Golden Visa and IFICI?
Yes. They are different instruments, decided by different authorities, and they do not exclude each other. Whether holding both is worth anything depends entirely on where you pay tax.
The Golden Visa is a residency permit. It lets you live and work in Portugal and asks you to spend very little time here. IFICI, the regime that replaced NHR, is a personal tax status. It only applies once you are a Portuguese tax resident, and it only rewards income from an eligible activity. One is about the right to be here. The other is about what happens if you actually are.
- YesThe two can be held at the same time
- 14 vs 183Days for the visa, days that make you tax resident
- 5 yearsYou must not have been tax resident here in the five before IFICI
- 15 JanuaryIFICI registration deadline, the year after you become resident
Two regimes, two authorities, one very common mistake
The Golden Visa is sold as a tax play by people who should know better. It is not one, and treating it as one is expensive in both directions.
AIMA grants one, the tax authority the other.
Your ARI is decided by AIMA’s board under the foreigners law. IFICI is registered with the tax authority through the Portal das Finanças, with your eligible activity certified by whichever body owns your category. Neither knows or cares about the other.
Law 23/2007 and Ordinance 352/2024/1Fourteen days a year changes nothing you pay.
Holding an ARI does not make you a Portuguese tax resident, and the minimum stay is far below the 183 day threshold. If you keep your tax residence elsewhere, Portugal taxes only Portuguese source income, and IFICI is irrelevant to you.
CIRS, Article 16Being an investor is not an eligible activity.
IFICI rewards income from one of the eligible categories, and passive investment is not among them. An investor who moves to Portugal and does nothing else has no eligible income, so nothing for the 20% rate to apply to and nothing to satisfy the annual test with.
Ordinance 352/2024/1, Article 2Four positions, and what each one actually costs you
Find yourself in this list before you decide anything. Most people are in the first row and think they are in the fourth.
- Golden Visa, tax resident elsewhere
- The standard case. You hold EU residency, spend your minimum days here, and Portugal taxes only Portuguese source income. IFICI adds nothing, because you are not a Portuguese tax resident
- Golden Visa, then Portuguese tax residence, no eligible activity
- The expensive case. You are taxed here on worldwide income at progressive rates reaching well above 20%, with no regime to soften it. Model this before you move, not after
- Golden Visa, Portuguese tax residence, and IFICI
- The good case, if you qualify. A flat 20% on qualifying Portuguese work income, most foreign income exempt, pensions excluded, and blacklisted jurisdictions taxed at 35%
- IFICI without a Golden Visa
- Common and often better. EU nationals cannot hold an ARI at all, and many non-EU arrivals come on a work or D visa. IFICI does not require the visa
- The bridge, for an investor who wants both
- A remunerated board seat in a company certified as a startup under Law 21/2023 is an eligible IFICI activity, with no qualification minimum attached to that category. It is the route that most often turns row two into row three
The trap is the five year look back, and a Golden Visa can spring it
IFICI requires that you were not a Portuguese tax resident in the five years before you become one. A Golden Visa holder who spends enough time here to become tax resident, perhaps without noticing, starts that five year clock. Move properly a few years later and IFICI is closed to you. If a Portuguese move is anywhere in your plan, count your days from the beginning and decide deliberately when tax residence starts.
Common questions
The ones we answer on almost every call, and the ones the market most often gets wrong.
Does a Golden Visa give me a tax benefit?
No. It is a residency permit. It does not change your tax residence, and it grants no reduced rate on anything. Any tax advantage comes from IFICI, which is a separate application to a separate authority and has its own conditions.
Do I have to move to Portugal to use IFICI?
Yes. IFICI applies to Portuguese tax residents, so it starts in the year you become one. Residence for tax purposes turns on more than 183 days in a twelve month period or having your habitual home here, under Article 16 of the personal income tax code.
I have held a Golden Visa for three years and now want to move. Can I still get IFICI?
Probably, provided you have not been a Portuguese tax resident during those years and have never used the non habitual resident regime or Programa Regressar. Holding the permit is not the problem. Having been tax resident is.
Which do I apply for first?
They are independent, so there is no required order. In practice the visa takes far longer, so it usually starts first, while IFICI is time-boxed to the year you become resident with registration due by 15 January of the following year. Missing that deadline shortens the ten year window rather than destroying it.
Can my spouse use IFICI too?
IFICI is personal, so each person is assessed on their own tax history and their own activity. One spouse qualifying does not extend the status to the other, and a spouse with no eligible activity gets no benefit from it.
Talk to us
This is the conversation we have most often, and it is the one where the two halves are usually advised separately by people who never speak to each other.
Book a call with Fernando
Fifteen or thirty minutes, by Microsoft Teams. Fernando Ferreira, General Partner at Ventures.eu.
