Portugal's incentives for Chinese investors: golden visa, IFICI, Madeira, SIFIDE

The golden visa after 2023

The residence permit for investment (autorização de residência para atividade de investimento, Lei n.º 23/2007, art. 3.º n.º 1 d)) lost its property routes on 7 October 2023, when Lei n.º 56/2023 revoked the 500 000 € purchase, the 350 000 € rehabilitation purchase and the 1,5 million € capital transfer. What remains, for applications since then:

The fund route dominates Chinese applications. Its tax profile is favourable while the investor stays non-resident: income and redemption gains from a Portuguese securities fund paid to a non-resident are exempt from Portuguese tax (EBF, art. 22.º-A n.º 1 d)) on proof of residence abroad — China’s own 20 % on the investor’s worldwide investment income then applies with nothing to credit. A golden visa does not by itself make you Portuguese tax resident; living here does, and only then do the regimes below matter.

• 500 000 € in a non-property fund or a job-creating company; property no longer qualifies
• 0 % Portuguese tax on fund income and gains for a non-resident holder; 28 % once resident, unless IFICI applies
• IFICI: 20 % for ten years on Portuguese income from listed activities, foreign income exempt, for newcomers not resident here in the previous five years
• 5 % IRC in the Madeira free zone until 2033 for companies licensed by 31 December 2026

IFICI, the successor of NHR

The non-habitual resident regime closed on 1 January 2024. Its replacement, the Incentivo Fiscal à Investigação Científica e Inovação (EBF, art. 58.º-A), applies to people who become tax resident without having been resident in Portugal in the previous five years and who earn income from a listed activity: higher-education teaching and research; qualified jobs under contractual investment incentives or in companies under the RFAI regime; highly qualified professions in listed industrial and service companies exporting at least 50 % of turnover; qualified jobs in companies recognised by AICEP or IAPMEI; R&D staff eligible for SIFIDE; jobs and board seats in certified start-ups; activities in the Azores and Madeira.

What it gives, for ten years: 20 % on the Portuguese employment or business income from the activity, and exemption with progression of foreign salaries, business income, dividends, interest, rents and gains (IRS Code, art. 81.º n.º 4). Pensions are excluded; income from listed tax havens is taxed at 35 %. Registration by 15 January of the year after arrival. For a Chinese entrepreneur who moves to run a Portuguese company that qualifies — a certified start-up, an exporter in a listed sector — the combination is a 20 % salary and untaxed Chinese dividends, with China’s 10 % treaty withholding as the only cost on the dividends.

Company-level incentives

• Madeira International Business Centre: companies licensed in the free zone by 31 December 2026 pay IRC at 5 % until 31 December 2033 on income from operations with non-residents, provided they create jobs (one to five jobs with 75 000 € of investment in the first two years, or six or more jobs) and within taxable-income ceilings tied to headcount (2,73 million € for one or two jobs, up to 205,5 million € above 100 jobs) (EBF, art. 36.º-A).
• SIFIDE II: a credit of 32,5 % of R&D spending plus 50 % of the increase over the previous two years’ average, up to 1,5 million € on the incremental part (Código Fiscal do Investimento, art. 38.º).
• RFAI: a credit of 30 % of qualifying investment up to 15 million € and 10 % above in eligible regions (CFI, art. 23.º).
• Participation exemption: dividends and gains on holdings of at least 10 % held twelve months are exempt for a Portuguese holding company (CIRC, art. 51.º), and dividends paid to a Chinese parent meeting the same test leave Portugal without withholding (CIRC, art. 14.º n.º 3).

What China does on its side

A Chinese resident who invests in Portugal remains taxable in China on the worldwide income: fund distributions and gains at 20 %, dividends at 20 % (with the Portuguese 10 % credited, or nothing when the Portuguese exemption applied), a Portuguese salary at the progressive rates with credit. Moving the money needs the SAFE channels — USD 50 000 a year of personal foreign-currency purchase without documents, more with proof of a current-account purpose, and approval for outbound direct investment (Implementing Rules on Individual Foreign Exchange Administration, art. 2, 14 and 16). A golden-visa subscription of 500 000 € is a capital-account transfer that Chinese banks scrutinise; the paperwork on the Chinese side is usually the slowest part of the file.

Steps

Questions