Cross‑Border Tax Forecast 2026 in Portugal

Effective from 2026 onwards.

Law no. 64/2025, dated 7 November 2025, was approved. This implemented phased decreases in the CIT rate to:

• 19% in 2026
• 18% in 2027
• 17% in 2028 (final).

The change delivers a lower CIT burden for businesses in Portugal.

N.A. 

Effective from 1 January 2026.

Ministerial Order No. 292/2025/1, dated 5 September 2025, amending Ministerial Order No. 150/2004 of 13 February, delisted Hong Kong, Liechtenstein and Uruguay from the Portuguese Tax Haven List. Aggravated tax rates and restrictions will no longer apply to situations involving these jurisdictions, and treaty benefits may apply to Hong Kong and Uruguay.

New opportunities for non-residents or Portuguese residents with exposure to these jurisdictions.

Review existing income flows and asset positions with exposure to these jurisdictions. 

Expected in the second semester of 2026.

Draft Law No. 47/XVII/1st, dated 9 January 2026, is currently under discussion. It foresees several tax measures to promote the increase of moderate rent/priced housing in the residential market. It includes changes to VAT, personal income tax, CIT, property taxes and Real Estate Transfer tax codes and other ad hoc measures.

The changes deliver tax benefits for landlords and tenants regarding the sale and purchase and lease of housing under moderate rents, as well as incentives for promoters and developers of housing projects. Some of these incentives will only be in force temporarily (until 2029).

Review new and ongoing housing projects and implement any necessary adjustments to ensure eligibility for these new tax incentives 

Expected in 2026.

Decision no. 249/25.3BEFUN dated 16 October 2025, issued by the Central Administrative Court (South), set an 8-year limitation period applicable to the recovery of State Aid by the Portuguese state from taxpayers in the Madeira Free Trade Zone. This decision is pending confirmation by the Supreme Administrative Court.

If confirmed by the Supreme Administrative Court, this change sees the potential annulment of CIT assessments issued by the Portuguese tax authorities for 2012, 2013 and 2014 to taxpayers with exposure to the Madeira Free Trade Zone.

N.A.