Portugal keeps an official list of countries, territories and regions it treats as having a clearly more favourable tax regime, commonly called its tax haven blacklist, and being connected to one can be costly. Certain categories of income connected with a listed jurisdiction can be subject to an aggravated 35% rate under specific Portuguese rules, and a Portuguese special tax regime does not automatically shelter it; the rate does not apply automatically to every asset, payment or transaction. Two groups are most affected: people who become resident in Portugal while still holding investments connected with listed jurisdictions, and Portuguese nationals who move to a listed territory such as the United Arab Emirates may continue to be treated as Portuguese tax resident, and therefore generally taxable on worldwide income, for the year of the move and the following four years, subject to the detailed rules, any acceptable-reasons exception and relevant treaty provisions. The UAE is still on the list in 2026, and a reported proposal to align the list with the EU’s may change matters in future but is not yet in force. This guide explains how the blacklist works, who it catches, and the traps worth understanding before you move or invest. If you want a clear view of your own position, we offer an initial, no-cost information-gathering conversation to identify what may need specialist Portuguese tax advice.
Portugal maintains an official list of countries, territories and regions it regards as having a clearly more favourable tax regime, commonly called the tax haven blacklist, set out in Portaria n.º 150/2004 and updated by later orders. Being connected to a listed jurisdiction can trigger aggravated tax treatment, but the treatment is not uniform. Certain dividends, interest and other specified investment income connected with an entity or jurisdiction on the list can be subject to a 35% rate under the applicable Portuguese rules. The treatment of capital gains depends on the asset, the taxpayer, the transaction and the specific statutory provision, and should not be assumed from the jurisdiction alone. There are also aggravated Portuguese property-tax rules in some cases. The purpose is to discourage the use of low-tax jurisdictions, but the effect can catch ordinary investors and movers who never set out to avoid tax, which is why the precise rule and category of income matter.
People often assume that a special Portuguese regime will protect them. A Portuguese special tax regime does not automatically override the specific anti-blacklist rules. The treatment depends on the regime, the category and source of the income, and the applicable statutory conditions. Individuals relying on transitional treatment under the former non-habitual resident regime, or on the newer IFICI regime where relevant, should obtain a specific Portuguese analysis rather than assume that the regime shelters income connected with a listed jurisdiction. So a new arrival who planned their Portuguese tax position carefully can still be caught if they hold legacy investments connected with a listed jurisdiction, and the point to check is the exact rule that applies to each item of income.
Many internationally mobile people hold investments connected with familiar financial centres for entirely practical reasons, several of which appear on Portugal’s current list; the current consolidated list should be checked for each jurisdiction as at the relevant date. Whether a particular item of income is treated as connected with a listed jurisdiction can depend on the residence of the payer or the entity, the structure of the investment and the specific Portuguese rule; the location of a platform or bank account alone may not determine the tax treatment. The investments may have been sensible when you acquired them, but they can interact badly with Portuguese residence. Reviewing which payers, entities or structures are connected with a listed jurisdiction, and taking Portuguese advice on whether to restructure before becoming resident, is one of the most valuable things to do in advance.
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The United Arab Emirates remains on Portugal’s list in 2026, and this creates a specific and often overlooked issue for Portuguese nationals. Under Article 16 of Portugal’s Personal Income Tax Code, a Portuguese national who moves their tax residence to a jurisdiction on the list may continue to be treated as Portuguese tax resident in the year of the move and the following four years, unless the statutory exception applies and acceptable reasons for the move are established. If the rule applies and no acceptable reason is established, Portuguese residents are generally taxed on worldwide income, subject to the detailed domestic rules, treaty provisions, exemptions, credits and the facts of the case. The legislation gives temporary employment in the territory for an employer domiciled in Portugal as an example of a potentially acceptable reason, but it is not an automatic safe harbour, and the facts, duration, employer and supporting evidence must be assessed individually, which matters particularly for someone moving to Dubai for a new UAE employer. On the treaty, its definition of an individual UAE resident requires UAE domicile and UAE nationality, so it may not allow a Portuguese national to qualify as a UAE resident for treaty purposes; that does not make the treaty irrelevant, as its separate income-allocation and double-tax-relief provisions still need to be reviewed. The treaty definition affects access to treaty residence status; it does not, by itself, determine every domestic-law consequence or eliminate the need to analyse the treaty’s income articles. The special rule can cease to apply where the statutory conditions are no longer met, including where the individual becomes tax resident in a jurisdiction that is not on the list; the timing and interaction with the ordinary residence rules should be checked under the current legislation. So a Portuguese citizen moving to Dubai can find the position is far less clear-cut than they assumed, which is exactly the kind of thing to plan for before the move, not after.
The list can reach property as well as income, but the precise rule matters. Portuguese property held or acquired through an entity resident in a jurisdiction on Portugal’s list can be subject to higher rates under specific IMI, IMT or related property-tax provisions. The applicable tax, rate and conditions depend on the property, the entity, the transaction and the statutory rule, so the structure should be reviewed by a Portuguese adviser rather than inferred from the existence of the list alone. Holding Portuguese property through a company resident in a listed jurisdiction can therefore produce a different and potentially more expensive tax result. Anyone holding, buying or restructuring Portuguese property through a non-Portuguese entity should take Portuguese advice on whether that entity is resident in a listed jurisdiction and which rules apply.
The list is not fixed. It is updated by ministerial order, and the most recent change removed Hong Kong, Liechtenstein and Uruguay with effect from 1 January 2026. Separately, on 25 June 2026 the Portuguese Council of Ministers approved a proposal for a law authorising the Government to revise the criteria used to identify jurisdictions with clearly more favourable tax regimes. The proposal refers to incorporating EU-listed non-cooperative jurisdictions and updating the criteria by reference to EU, OECD and G20 standards, so it may change which jurisdictions are listed in either direction rather than simply replacing or shrinking the list. As at the review date, it had not changed the current list. The final legislation, implementing measures, effective date and treatment of particular jurisdictions, including the UAE, remain to be confirmed. Until any new legislation is enacted and takes effect, the current Portuguese list and rules continue to apply, so the position should not be planned around a change that has not happened.
Portugal’s blacklist catches two kinds of people who never thought it applied to them: people who move to Portugal still holding perfectly sensible investments connected with listed jurisdictions, and Portuguese nationals who move somewhere like Dubai and assume they have left Portuguese tax behind. The special residence rule for Portuguese citizens moving to a listed place is the one that shocks people: you may continue to be treated as Portuguese tax resident and potentially taxable in Portugal on worldwide income for the relevant period, subject to the statutory exceptions and treaty analysis. A reported change may help in future, but it is not here yet. If Portugal is on either end of your move, check the position before you commit.
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A Portuguese special tax regime does not automatically override the anti-blacklist rules; whether income connected with a listed jurisdiction is sheltered depends on the regime, the category and source of income and the statutory conditions. Planning a Portuguese move around a favourable regime, without checking which of your payers, entities or structures are connected with a listed jurisdiction, can leave a large gap.
Investments connected with places like Jersey, the Isle of Man or the Cayman Islands can be sensible in themselves, but those jurisdictions are on Portugal’s current list. Becoming Portuguese resident without reviewing which payers, entities or structures are connected with a listed jurisdiction can turn certain investment income into income potentially subject to the aggravated 35% rate.
The treaty may not provide the residence protection expected, because its definition of an individual UAE resident requires UAE domicile and UAE nationality; but it is not irrelevant, and its income-allocation and relief provisions still need reviewing. A Portuguese citizen moving to the UAE can continue to be treated as Portuguese resident, and so generally taxable on worldwide income subject to the rules and treaty, for the year of the move and the following four years.
The reported proposal to align Portugal’s list with the EU list is not yet in force, and it is not certain which jurisdictions would come off or when. The current list, including the UAE, still applies, so do not plan on the basis of a change that has not happened.
Portuguese property held through an entity resident in a listed jurisdiction may attract aggravated treatment under specific property-tax rules. A structure that looked efficient can be costly, so the entity’s residence and the applicable rules should be checked with Portuguese advice.
Illustrative example only, not a real client and not a guarantee of any outcome. This illustration is simplified and omits facts that could materially change the outcome. Miguel, a Portuguese citizen, took a job in Dubai and moved there, expecting that once he was living and working in the UAE he would be outside Portuguese tax and would benefit from the UAE having no personal income tax. He also kept an investment portfolio held through a platform in a well-known offshore centre. He had not heard of Portugal’s tax haven blacklist or the five-year rule.
A review flagged two issues, on assumed facts about his nationality, actual residence, employment arrangement, acceptable-reasons evidence and portfolio structure. First, because the UAE is on Portugal’s list and Miguel is a Portuguese national, the special rule in Article 16 of the Personal Income Tax Code could continue to treat him as Portuguese tax resident, and so generally taxable on worldwide income subject to the rules and treaty, for the year of his move and the following four years, unless acceptable reasons for the move were established; the treaty’s definition of an individual UAE resident might not provide the residence outcome he expected, although the treaty would still need to be reviewed for income-allocation and double-tax-relief purposes. Second, specified income from his portfolio could be subject to an aggravated rate, depending on the identity and residence of the payer or entity and the applicable Portuguese rule, if he continued to be treated as Portuguese tax resident and the relevant domestic rule applied. The review set out the questions to put to a qualified Portuguese tax adviser, including whether acceptable reasons for the move could be established and how the timing worked.
Rather than assume his move had taken him cleanly out of Portuguese tax, Miguel used the review to understand the five-year rule and the blacklist exposure, and took the detail to a qualified Portuguese tax adviser to plan around before filing anything. A review of this kind does not give Portuguese tax advice or guarantee a result; it identifies the issues so the right specialist can act on them.
Illustrative example, not a real client.
Clarity Global Wealth helps internationally mobile people understand how Portugal’s tax haven blacklist might affect them before they move or invest. We help you identify the questions to put to a qualified Portuguese tax adviser, including whether the relevant payer, entity or investment structure is connected with a jurisdiction on the current list, whether specific aggravated-tax rules may need to be considered, whether a Portuguese special regime is likely to help, and, for Portuguese nationals moving to a listed territory such as the UAE, how the special residence rule and the treaty might apply. Because Portuguese tax is specialist and jurisdiction-specific, we coordinate with qualified Portuguese tax advisers rather than giving that advice ourselves. We offer an initial, no-cost information-gathering conversation to identify questions that may require specialist Portuguese tax advice; it is not a tax calculation, legal opinion, tax-return preparation service or personal recommendation. Our role is to give you a clear, honest picture and the questions to resolve, ideally before a move rather than after.
Related guides: Tax in Portugal for Expats, Becoming Tax Resident in the UAE, and Returning to the UK After Living Abroad.
This guide is provided for general information only and reflects our understanding of the rules as at the date of publication. It is not personal financial, investment, pension or tax advice, and should not be relied upon as such. Rules and tax treatment can change and depend on your individual circumstances and country of residence. You should always seek regulated advice specific to your situation before taking action.
It is an official Portuguese list of countries, territories and regions treated as having a clearly more favourable tax regime, set out in Portaria n.º 150/2004 as amended. Being connected to a listed jurisdiction can trigger aggravated Portuguese tax treatment for certain income and property, but the treatment is not uniform and depends on the specific rule, the category of income and the facts.
No. Certain categories of income, such as specified dividends, interest and other investment income connected with an entity or jurisdiction on the list, can be subject to an aggravated 35% rate under the applicable Portuguese rules. The rate does not apply automatically to every asset, payment or transaction, and whether it applies depends on the payer, entity, structure and the specific statutory provision.
Yes. The United Arab Emirates remains on Portugal’s current list in 2026 (item 22 of Portaria n.º 150/2004). The recent amendment removed Hong Kong, Liechtenstein and Uruguay from 1 January 2026 but did not remove the UAE.
Possibly. Under Article 16 of Portugal’s Personal Income Tax Code, a Portuguese national who moves to a listed jurisdiction may continue to be treated as Portuguese tax resident, and so generally taxable on worldwide income subject to the rules and treaty, for the year of the move and the following four years, unless the statutory exception applies and acceptable reasons are established. The Portugal to UAE treaty may not allow you to qualify as a UAE resident for treaty purposes, but still needs reviewing. Take Portuguese advice before you move.
It is not certain. On 25 June 2026 the Portuguese Council of Ministers approved a proposal for a law authorising revision of the criteria for identifying listed jurisdictions, referencing EU, OECD and G20 standards. It may change which jurisdictions are listed in either direction and was not enacted as at the review date. Until any new legislation takes effect, the current list, including the UAE, continues to apply.
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