Law No. 13/2026, of 16 April, has authorised the Portuguese Government to extend SIFIDE II to the 2026 tax period — but without renewing the possibility of accessing the benefit indirectly through investment funds.
In practice, this route, used by many companies and investors, will no longer generate new tax benefits, leaving the incentive focused on R&D investment made directly by companies.
What is SIFIDE II
The Tax Incentive System for Corporate Research and Development (“SIFIDE II”) is one of Portugal’s main tax instruments supporting corporate investment in research and development (“R&D”). It allows companies to deduct part of their eligible R&D expenses from their corporate income tax (“IRC”) assessment — namely research expenses related to acquiring new scientific or technical knowledge, and development expenses aimed at applying that knowledge to discover or substantially improve raw materials, products, services or processes.
How the benefit can currently be accessed
Access to SIFIDE currently works through two routes:
- Direct SIFIDE: where the company itself incurs eligible R&D expenses
- Indirect SIFIDE: where the R&D investment is made through contributions to investment funds that finance companies primarily engaged in R&D activities, under the terms of the Investment Tax Code
It is this second route that is affected by the change now announced.
What changes
Law No. 13/2026 introduces two particularly relevant changes:
- It extends SIFIDE II to the 2026 tax period; and
- It does not renew the possibility of accessing the benefit indirectly through investment funds
In other words, SIFIDE II is extended, but the legislative intent is clear: the tax benefit associated with indirect investment through funds is not meant to follow that extension. The change will be implemented by the Government under the legislative authorisation granted by Parliament.
Impact for companies and investors
The change matters for companies and investors that have used investment funds as an indirect route into SIFIDE. Once implemented, the incentive will be essentially limited to R&D investment made directly by companies, and it will no longer be possible to generate new SIFIDE benefits through contributions to funds under the terms currently in place.
Law No. 13/2026 does, however, provide for rules intended to safeguard investments already made. It will therefore be particularly important to distinguish between new contributions to funds and investments already carried out under the regime currently in force.
How can we help
VCA closely follows the evolution of this regime and advises companies and investors on the impact of this change, including how to distinguish between investments already made and new contributions. We are available to clarify the practical implications for each specific case.
Tax Department
João Valadas Coriel | Sofia Quental | Inês Grácio | Catarina Amaral
