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News and developments

Update to the Portuguese list of tax havens

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/

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