On September 5, 2025, the Portuguese Government approved Ministerial Order n.º 292/2025/1.
This decree removes the Special Administrative Region of Hong Kong, China, the Principality of Liechtenstein, and the Oriental Republic of Uruguay from Portugal’s tax blacklist. The change will apply from January 1, 2026.
What Is the Portuguese Tax Blacklist?
To begin with, Portugal maintains a list of countries with “clearly more favourable” tax regimes.
This blacklist affects how Portuguese resident taxpayers are taxed when dealing with these jurisdictions.
As a result, transactions with blacklisted countries often face higher tax rates and tighter reporting rules.
Why Were These Jurisdictions Removed?
Furthermore, Hong Kong, Liechtenstein, and Uruguay asked Portugal to review their blacklist status.
The Portuguese Tax Authority reviewed the requests and confirmed they no longer meet blacklist criteria.
In addition, these jurisdictions are not on the EU list of non-cooperative tax jurisdictions.
Benefits for Portuguese Residents: Tax Savings
Consequently, resident taxpayers in Portugal will enjoy several benefits from this update, namely:
- Real estate investments: Non-resident investors (individuals or companies) no longer face the punitive tax treatment for property tax purposes.
- Cross-border payments: Portuguese companies making payments (interest, royalties, service fees) to these jurisdictions should no longer face denial of deductibility and/or 35% autonomous taxation.
- Withholding taxes: withholding taxes on dividends, interest, and royalties will follow domestic law and treaty rules (when applicable).
- Inbound dividends and capital gains regime (participation exemption) for entities in those jurisdictions.
- Income sourced in those jurisdictions is exempt under the NHR 2.0. regime (IFICI).
Conclusion
In summary, the Portugal tax blacklist update brings welcome relief for taxpayers.
From 2026, dealing with Hong Kong, Liechtenstein, and Uruguay will be simpler and more tax-efficient. Therefore, residents can explore global opportunities without unnecessary tax penalties.
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