How Portugal Taxes Trust Income

In this episode, we break down Portugal’s newly updated list of “tax haven” jurisdictions for 2025, which now excludes Hong Kong, Liechtenstein, and Uruguay. These updates reflect Portugal’s ongoing effort to align its tax transparency framework with OECD and EU standards, while maintaining one of Europe’s more comprehensive blacklists.

We explore what this means for investors, companies, and advisors working with Portuguese structures — and how this change fits within broader global blacklisting trends.

🧩 Key Topics Covered

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• What Is a “Blacklist”?
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• An overview of how countries use jurisdictional blacklists to discourage tax evasion, treaty abuse, and opaque structures.
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• Portugal’s 2025 Update:
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• • Removed: Hong Kong, Liechtenstein, and Uruguay
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• • Still Included: A long list of traditional offshore centers such as Anguilla, Bahamas, Barbados, BVI, Cayman Islands, Panama, Seychelles, and more.
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• EU Context:
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• The EU blacklist currently includes jurisdictions like American Samoa, Anguilla, Panama, Russia, and Vanuatu.
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• The EU grey list includes Armenia, Belize, BVI, Costa Rica, Curaçao, Malaysia, Seychelles, Turkey, and Vietnam.
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• Portugal’s Distinct Approach:
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• Portugal maintains its own national list, which can differ from the EU’s, impacting withholding tax rates, deductibility of expenses, and CFC (Controlled Foreign Company) rules.
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• International Alignment:
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• Portugal has signed agreements to comply with OECD standards on exchange of information and BEPS (Base Erosion and Profit Shifting) recommendations.
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💡 Why It Matters

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• Tax Consequences:
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• Transactions involving blacklisted jurisdictions can trigger increased withholding taxes (often 35%), deductibility restrictions, and reporting obligations.
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• Compliance Impact:
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• Removal of Hong Kong, Liechtenstein, and Uruguay means lower compliance friction for inbound investments and greater alignment with EU standards.
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• Strategic Planning:
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• Advisors and multinational structures should review their Portuguese CFC exposure and related-party transactions in light of the new list.
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🧠 Key Takeaways

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• Portugal’s list remains among Europe’s broadest and most restrictive, despite the 2025 relaxations.
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• The exclusion of Hong Kong, Liechtenstein, and Uruguay signals Portugal’s recognition of improved tax transparency in those jurisdictions.
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• Investors using offshore entities in connection with Portuguese assets should review whether their structures still fall under “blacklist” consequences.
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• Expect continued EU pressure for consistency across member-state lists in 2026.
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🔍 Mentioned in This Episode

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• Portugal Ministry