Anexo L (IRS): how to declare your NHR or IFICI

Inês works remotely for a company abroad and has non-habitual resident status. She opens her IRS declaration, sees her income already entered in its usual annexe, and breathes out. Then the system asks her to type the same income again, this time somewhere called “Anexo L”. Her first reaction is everyone’s reaction: is this a bug?

It isn’t. Repeating the income is exactly how the regime is claimed. If Anexo L isn’t filled in, the benefit simply doesn’t apply: you are taxed as an ordinary resident on income that, under the regime, could be exempt or taxed at a reduced rate.

Let’s go through, step by step, what Anexo L does and where it’s easy to slip up.

What Anexo L is and why you repeat the income

Anexo L is where you declare that you have RNH (residente não habitual, non-habitual resident) or IFICI status, and the tax option for your high-value-added income. Only someone registered as a beneficiary of one of these regimes files it. Having RNH is a right, not an obligation.

The part that confuses everyone: Anexo L does not replace the other annexes. The income is still declared in its base annexe (A for salary, B for recibos verdes, J for foreign income) and it is mirrored in Anexo L. It isn’t redundancy or over-declaring; it’s how the AT knows which already-declared income the regime applies to.

In practice: high-value-added Category A income goes in Anexo A and in quadro 4A of Anexo L; Category B (simplified regime) goes in Anexo B and in quadro 4B (organised accounting uses Anexo C); foreign employment or self-employment income from high-value-added activities goes in Anexo J and is mirrored in quadro 5 of Anexo L (RNH only). Quadro 5A even refers to Anexo J by line number. Other foreign income, such as rents or capital gains, stays in Anexo J only (though under RNH the method to relieve double taxation on it is chosen in quadro 6C of Anexo L). Forget the base annexe and you under-declare; forget Anexo L and you lose the regime.

Before going further, one distinction that avoids the most common mistake. The choice between 20% and englobamento, coming up next, is for your Portuguese-source high-value-added income (the work you do here). Foreign-source income (for example, a salary earned while physically working abroad) follows a different path: under RNH it is generally removed from double taxation by exemption or a tax credit (depending on the category and source country), an option ticked in quadro 6C that has nothing to do with the 20% rate. That part is more technical; if it’s your case, check with an accountant.

The 20% rate or englobamento: the choice you can’t get wrong

Once you’ve identified the income, Anexo L asks how you want it taxed. This is the costliest choice to get wrong.

• Tributação autónoma: applies the 20% special rate to high-value-added income. This is the benefit of the regime.
• Englobamento: instead of the 20%, the income goes through the progressive brackets, like any other taxpayer’s. At lower incomes, it’s sometimes cheaper.

Where people slip up: in quadro 6A (RNH) you tick Category A in field 01 (autónoma) or 02 (englobamento), and Category B in field 03 or 04. In quadro 7 (IFICI) the fields are the same, 01 to 04. Someone in a rush who ticks englobamento thinking they’re “choosing the benefit” accidentally moves the income onto the progressive rate. Note too that opting for englobamento drags all of that category’s income into the brackets, not just the high-value-added part.

One important trap, and it differs by regime: under RNH, the 20% rate only applies to income from a high-value-added activity on the official list (the Portaria of high-value-added activities) - if yours isn’t there, it’s taxed under the general regime. Under IFICI there is no single professions list: eligibility runs through several grounds of EBF art. 58.º-A (research and higher-education teaching; jobs in certified startups; qualified jobs or management-body members in entities recognised by AICEP/IAPMEI; R&D personnel whose costs qualify for SIFIDE) - the professions list counts for only one of those grounds. In other words, you can qualify for IFICI without being on a “professions list”. If in doubt, check before you count on the benefit.

RNH or IFICI? They’re not the same thing

In quadro 1 of Anexo L you tick which regime is yours: field 01 = RNH, field 02 = IFICI. They’re different regimes and mutually exclusive.

• RNH (art. 16.º of the CIRS) is closed to new entrants since it was revoked by the 2024 State Budget. A transitional regime keeps it for those who already qualified by the end of 2023/2024.
• IFICI (art. 58.º-A of the EBF) replaced RNH from 2024, but it’s narrower: it covers only specific activities (research, innovation, highly qualified roles in certain entities), not every new resident. It runs for 10 consecutive years.
• You can’t have both. You can’t get IFICI if you had (or have) RNH, or if you used the Programa Regressar.

Watch out for a common mistake: under RNH, the 20% rate applies to high-value-added income in Categories A and B. Under IFICI, the rate is far more tightly tied to specific activities and entities and, for most ordinary recibos verdes, it doesn’t automatically translate into 20% on your freelance income. If you’re on IFICI and self-employed, don’t assume “IFICI = 20% on my recibos verdes”: it depends on your eligible activity. This is territory for a consultant. If you’re still working out what RNH is and how to get started, we have a more introductory piece on opening an activity as a foreigner in Portugal.

Warning: the costliest mistake is thinking Anexo L replaces the base annexe. It doesn’t: forget Anexo A/B/J and you under-declare; forget Anexo L and you lose the regime. The second mistake is ticking englobamento when you wanted the 20%, which silently swaps the benefit for the progressive rate. The regime, eligibility (the high-value-added list, IFICI) and double taxation are complex matters: a mistake here costs you the difference between 20% and the progressive rate. If in doubt, check with a consultant before you submit.

✅ In summary

1. Anexo L declares the regime, not the income: the income goes in the base annexe (A, B or J) and, where applicable, is mirrored in Anexo L. In quadro 1 you tick RNH (field 01) or IFICI (field 02). Forget either side and you either under-declare or lose the benefit.

2. The choice you can’t get wrong is autónoma (20%) vs englobamento: tributação autónoma applies the 20% special rate to high-value-added income; englobamento sends it to the progressive brackets. You tick the option in quadro 6A (RNH) or 7 (IFICI), fields 01 to 04. Eligibility for the 20% differs: under RNH it depends on the official high-value-added activities list; under IFICI, on the several grounds of EBF art. 58.º-A (activity and entity), not a single professions list.

3. With FIZ your Anexo L is filled in for you: the system pulls your RNH status from the AT portal, applies the 20% rate and the double-taxation relief method to foreign income, shows you the “with NHR vs without NHR” comparison, and you submit the declaration directly on the AT portal (or upload the XML by hand). FIZ helps you declare the regime, but whether you’re eligible in the first place is a separate question, one for a consultant. See the plans.