08/09/2025
Ministerial Order no. 292/2025, of 5 September, has amended Ministerial Order no. 150/2004, of 13 February, excluding the following jurisdictions from Portugal’s list of countries, territories, and regions with clearly more favourable tax regimes:
- Hong Kong Special Administrative Region
- Principality of Liechtenstein
- Oriental Republic of Uruguay
The decision results from formal requests submitted by the Governments of the respective jurisdictions under Article 63.º-D(3) of the Portuguese General Tax Law, which received a favourable opinion from the Portuguese Tax Authority. It should also be noted that these jurisdictions are not included in the European Union list of non-cooperative jurisdictions for tax purposes.
Effective as from 1 January 2026.
Key practical implications
Personal Income Tax – taxation of individuals
- Capital income (interest, dividends) and certain capital gains will no longer be subject to aggravated tax rates when sourced from these jurisdictions.
- Individuals qualifying for the Tax Incentive for Scientific Research and Innovation regime (TISRI or NHR 2.0) may now benefit from exemption on income sourced in these jurisdictions.
Corporate Income Tax – taxation of corporate entities
- The automatic non-deductibility of expenses and the aggravated autonomous taxation at 35% on payments to entities located in these jurisdictions will no longer apply.
- Dividends and capital gains from shareholdings in entities resident in these jurisdictions may benefit from the participation exemption regime (Article 51.º Corporate Income Tax Code).
Property taxes
Real estate held by entities located in these jurisdictions will no longer be subject to the increased municipal property tax rate (7.5%) or to additional restrictions under municipal property transfer tax.
Legal certainty and international alignment
This amendment brings the Portuguese list closer to the EU list of non-cooperative jurisdictions, enhancing legal certainty and reducing fiscal and reputational barriers for investments involving Hong Kong, Liechtenstein, and Uruguay.
Despite this update, 77 jurisdictions remain listed.
https://belim.pt/en/news-articles/news/update-to-the-portuguese-list-of-tax-havens/