Ordinance No. 292/2025/1, of September 5, has updated the list of countries, territories, and regions with clearly more favorable tax regimes—the so-called “tax havens”—amending Ordinance No. 150/2004, of February 13.

Following formal requests submitted to the Portuguese Government to review the aforementioned list, and supported by a favorable technical opinion from the Portuguese Tax Authority, the following jurisdictions have been excluded:

No. 31) Hong Kong Special Administrative Region;

No. 40) Principality of Liechtenstein;

No. 79) Oriental Republic of Uruguay.

The exclusion of these jurisdictions from the list of countries, territories, or regions with clearly more favorable tax regimes will eliminate the tax “penalties” currently applicable to transactions carried out with entities resident therein. It also opens the door for a reassessment of current and future investment structures involving these jurisdictions. Specifically, this change means that the increased 35% withholding tax rate on capital income - under both Personal Income Tax (IRS) and Corporate Income Tax (IRC) - will no longer apply. Likewise, higher rates of Municipal Property Tax (IMI), Property Transfer Tax (IMT), and Additional Municipal Property Tax (AIMI) will also cease to apply in such cases.

It is also worth noting that these jurisdictions are not included in the European Union’s list of non-cooperative jurisdictions for tax purposes, as approved by the Council of the European Union.

Ordinance No. 292/2025/1 entered into force on September 6 and will take effect from January 1, 2026.