Portugal trims its blacklisted jurisdictions list: Hong Kong, Liechtenstein & Uruguay delisted (effective 2026)

Portugal has removed Hong Kong, Liechtenstein, and Uruguay from its list of jurisdictions with “clearly more favourable” tax regimes. The measure was published on 5 September 2025 and applies from 1 January 2026.

This change follows formal requests by those jurisdictions and a positive opinion from the Tax Authority, and it aligns with the European Union list of non-cooperative jurisdictions, which does not include those three.

The full list is available here.

 

What changes?

Ministerial Order 292/2025 removes Hong Kong, Liechtenstein, and Uruguay from Portugal’s blacklisted jurisdictions. The Order enters into force the day after publication and produces effects from 1 January 2026.

 

Precedents of delisting and EU context

Andorra was delisted by Ministerial Order 309-A/2020, effective 1 January 2021.

On 18 February 2025, the Council of the EU confirmed the EU Annex I list with eleven jurisdictions, without changes and none of the three delisted by Portugal are on it.

 

Trade & investment impact

Cross-border payments: No automatic “blacklist” penalties on deductibility or aggravated taxation solely due to payee location. Standard rules and TP/substance tests apply.

Withholding tax: Domestic and treaty rates (dividends, interest, royalties) apply instead of aggravated rates due to blacklisted status.

Participation exemption regime: The Portuguese regime will apply without restrictions to inbound and outbound

Real estate: The punitive “offshore” Property Tax and Property Transfer Tax is set aside for these jurisdictions.

This change may also be viewed as policy signal and alignment with the EU non-cooperative jurisdictions list. It follows formal delisting requests assessed positively by the Portuguese Tax Authority.

 

Takeaways for businesses and investors

Review payment chains (services, interest, royalties) and pricing models.

Reassess holding and real-estate SPVs for potential efficiency gains.

Revisit treaty relief and participation-exemption eligibility for inbound/outbound dividends/capital gains (case-by-case).

 

Timings

For transactions up to 31 December 2025, the current list still applies, as delisting only takes effect from 1 January 2026.

 

How does a jurisdiction get blacklisted?

Among other tests, a jurisdiction could be listed if its corporate income tax was under 60% of Portugal’s standard rate, if its rules diverged strongly from international norms, if it had special low-tax regimes, or if effective information exchange was lacking.

For additional information or clarification, please feel free to contact us. Our Tax team and Private Client teams are ready to assist you.

 

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