5 September 2025
Framework
The Ordinance no. 292/2025/1, of 5 September, was published in the Official Gazette, amending Ordinance no. 150/2004, of 13 February, regarding the list of countries, territories or regions with a clearly more favourable tax regime (commonly referred to as the “tax haven” blacklist).
Main changes
The following jurisdictions are removed from the list:
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Hong Kong
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Liechtenstein
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Uruguay
This exclusion results from formal requests submitted by these jurisdictions and subsequent positive opinions issued by the Portuguese Tax and Customs Authority, which considered that the criteria justifying their inclusion on the list were no longer met.
Additionally, it should be noted that these jurisdictions are not included in the European Union list of non-cooperative jurisdictions for tax purposes (updated on 18 February 2025).
Tax impacts
This removal may allow for:
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Elimination of tax penalties (currently applicable to transactions carried out with entities resident in these jurisdictions);
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The possibility of reassessing investment structures (both existing and future).
Entry into force
The Ordinance enters into force on the day following its publication, that is, on 6 September 2025.
However, it only produces effects as from 1 January 2026.
Next steps
We are at your disposal to provide comprehensive support, including tailored advice and detailed clarifications on the implications of these changes for operations and investments.
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The above information is not intended to be an exhaustive analysis of all the changes to the current legal regime, but a selection of those that we believe to be the most relevant, and does not dispense with the consultation of our Company and/or diplomas to which they refer.
For more information contact: Catarina Breia (+351 91 7575 832 or cbreia@pt-nexia.com) from our Tax Department.
