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The removal of Hong Kong, Liechtenstein, and Uruguay from the Portuguese list of jurisdictions with a privileged tax regime, in force since 1 January 2026, introduces relevant changes to the tax framework applicable to economic relations with these jurisdictions, with potential positive impacts on investment and on the attractiveness of the Portuguese market.
In statements to Jornal de Negócios, Tânia de Almeida Ferreira, Partner in the Tax practice at CCA Law Firm, explains that the removal of these jurisdictions from the blacklist allows for a significant reduction in the tax burden associated with operations involving entities resident therein, namely through lower withholding tax rates on dividends, interest, and royalties, the elimination of aggravated taxation for IMT and IMI purposes, and the possibility of exemption from capital gains tax on the sale of Portuguese companies, albeit subject to certain exceptions.
In this context, the lawyer draws attention to the size and rigidity of the Portuguese list of tax havens, arguing for closer alignment with European practices and with the evolution of international tax transparency mechanisms. As she notes, “Portugal followed the easiest path: it listed countries that have tax regimes that are generally more favourable than the Portuguese one, assuming that any activity involving one of those countries constitutes tax evasion”, which, in her view, contributes to a framework that is misaligned with current reality.
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