Portugal's Council of Ministers has approved an amendment to the General Tax Law replacing the country's list of 77 countries, territories and regions with privileged tax regimes with the EU list of 10 non-cooperative jurisdictions, narrowing the scope of existing anti-abuse tax measures.
Portugal’s Council of Ministers has approved an amendment to the General Tax Law to replace the country’s existing list of countries, territories and regions with privileged tax regimes with the EU list of non-cooperative jurisdictions, aligning its blacklist with the European Union’s framework.
The amendment will reduce the number of jurisdictions subject to Portugal’s anti-abuse tax measures, from 77 under the current national list to 10 under the EU list. Under the existing rules, jurisdictions on Portugal’s blacklist are subject to a range of tax consequences, including a 35% withholding tax on dividends, interest and royalties, as well as ineligibility for Portugal’s participation exemption.
Portugal’s blacklist was established under Ministerial Order (Portaria) No. 150/2004 as a measure to combat international tax evasion and fraud. The list applies across several tax regimes, including IRS (Personal Income Tax), IRC (Corporate Income Tax), Stamp Duty, IMI and IMT, and has been updated periodically through subsequent amendments.
The government has not yet announced when the revised framework will take effect or how the transition will be implemented. Further details are expected to be published once the implementing measures are finalised.
