Portugal maintains an official blacklist of countries and jurisdictions considered for legal and tax purposes as tax havens. The purpose of this list is countering tax avoidance and evasion. Many of these countries in the list have double taxation agreements and committed to exchange of information under OECD tax exchange.
The disadvantages of investing from a blacklisted country for golden visa are..
- Funds domiciled in tax havens attract higher taxes. Higher withholding tax, 35% tax rate, on capital income (interests and dividends) deriving from investment funds.
- Increased scrutiny of banking and business transactions and possibly rejections.
- Difficulty in getting loans from Lenders in Portugal
- Aggravated municipal property tax of 7% on property owned by entities from blacklisted tax havens. The stamp duty rate for property owners and companies resident in tax havens pay higher 7.5% (instead of 1%).
- No NHR Benefits – Non-habitual residents (NHRs) status holders do not benefit from personal income tax exemption on interests, dividends, capital gains, income from immovable property (rents), royalties, intellectual property income and business income) if: these are sourced from black-listed jurisdictions. Therefore, taxation of such income will be subject to the normal rates or to the 35% rate depending on the type of income earned by the NHR status holder.
P.S: Carefully note there are countries that run citizenship by investment programs in the blacklist. This could affect those who acquired CBI passport then investing in Portugal golden visa.
List of Tax Havens
| Blacklisted Jurisdiction | Country / Territory | Double Taxation / Exchange |
| American Samoa | Unincorporated and unorganized U.S. territory | Portugal has signed an Agreement to Avoid Double Taxation with the country. |
| Anguilla | British Overseas Territory | – |
| Antigua and Barbuda | Country | – |
| Aruba | Constituent Country | – |
| Bahamas | Country | |
| Bahrain | Country | Portugal has signed an Agreement to Avoid Double Taxation with the country. |
| Barbados | Country | Portugal has signed an Agreement to Avoid Double Taxation with the country. |
| Belize | Country | – |
| Bermuda | British Overseas Territory | Portugal has signed an agreement of exchange of tax information with the territory. |
| Bolivia | Country | – |
| British Virgin Islands | British Overseas Territory | – |
| Brunei | Country | – |
| Cayman Islands | British Overseas Territory | Portugal has signed an agreement of exchange of tax information with the territory. |
| Christmas Island | Australian external territory | – |
| Cocos (Keeling) Islands | Australian external territory | – |
| Cook Islands | Country | – |
| Costa Rica | Country | – |
| Djibouti | Country | – |
| Dominica | Country | – |
| Eswatini | Country | – |
| Falkland Islands | British Overseas Territory | – |
| Fiji | Country | – |
| French Polynesia | Overseas country and collectivity of France | Portugal has signed an Agreement to Avoid Double Taxation with the country but the agreement does not include this territory. |
| Gambia | Country | – |
| Gibraltar | British Overseas Territory | Portugal has signed an agreement of exchange of tax information with the territory. |
| Grenada | Country | – |
| Guam | Unincorporated and organized U.S. territory | Portugal has signed an Agreement to Avoid Double Taxation with the country. |
| Guernsey | Bailiwick | Portugal has signed an agreement of exchange of tax information with the territory. |
| Guyana | Country | – |
| Honduras | Country | – |
| Hong Kong, China | Special Administrative Region | Portugal has signed an Agreement to Avoid Double Taxation with the territory. |
| Iran (Qeshm Island) | County | Only the county of Qeshm, more specifically the island of Qeshm has been blacklisted by the Portuguese government. |
| Isle of Man | Crown dependency | Portugal has signed an agreement of exchange of tax information with the territory. The Isle of Man was briefly whitelisted between January 1, 2017 and December 31, 2018. |
| Jamaica | Country | – |
| Jersey | Bailiwick | Portugal has signed an agreement of exchange of tax information with the territory. |
| Jordan | Country | – |
| Kiribati | Country | – |
| Kuwait | Country | Portugal has signed an Agreement to Avoid Double Taxation with the country. |
| Labuan | Malaysian Federal Territory | – |
| Lebanon | Country | – |
| Liberia | Country | – |
| Liechtenstein | Country | – |
| Maldives | Country | – |
| Marshall Islands | Country | – |
| Mauritius | Country | – |
| Mauritius | Country | – |
| Monaco | Country | – |
| Monaco | Country | – |
| Montserrat | British Overseas Territory | – |
| Nauru | Country | – |
| Netherlands Antilles | Constituent Country | The Netherlands Antilles were dissolved in 2010. |
| Niue | Country | – |
| Norfolk Island | Australian external territory | – |
| Northern Mariana Islands | Commonwealth | – |
| Oman | Country | Portugal has signed an Agreement to Avoid Double Taxation with the country. |
| Other Pacific Islands | Non-specified | The Portuguese Government considered “other Pacific Islands” all the islands in the Pacific Ocean not mentioned in the list. |
| Palau | Country | – |
| Panama | Country | – |
| Pitcairn Islands | British Overseas Territory | – |
| Puerto Rico | U.S. Commonwealth and Unincorporated and organized U.S. territory | Portugal has signed an Agreement to Avoid Double Taxation with the country. |
| Qatar | Country | Portugal has signed an Agreement to Avoid Double Taxation with the country. |
| Saint Helena, Ascension and Tristan da Cunha | British Overseas Territory | – |
| Saint Kitts and Nevis | Country | – |
| Saint Lucia | Country | – |
| Saint Pierre and Miquelon | Overseas collectivity of France | Portugal has signed an Agreement to Avoid Double Taxation with the country but the agreement does not include this territory. |
| Saint Vincent and the Grenadines | Country | – |
| Samoa | Country | – |
| San Marino | Country | Portugal has signed an Agreement to Avoid Double Taxation with the country. |
| Seychelles | Country | – |
| Solomon Islands | Country | – |
| Svalbard and Jan Mayen | Unincorporated internal area of Norway | Portugal has signed an Agreement to Avoid Double Taxation with the country but the agreement does not include these territories. |
| Tokelau | Dependent territory of New Zealand | – |
| Tonga | Country | – |
| Trinidad and Tobago | Country | – |
| Turks and Caicos Islands | British Overseas Territory | – |
| Tuvalu | Country | – |
| United Arab Emirates | Country | Portugal has signed an Agreement to Avoid Double Taxation with the country. |
| United States Virgin Islands | Unincorporated and organized U.S. territory | – |
| Uruguay | Country | Portugal has signed an Agreement to Avoid Double Taxation with the country. Uruguay was briefly whitelisted between January 1, 2017 and December 31, 2018. |
| Vanuatu | Country | – |
| Yemen | Country | – |
EU Blacklist
In addition to Portugal, the EU also has a separate blacklist of uncooperative tax havens, worth looking into 11 countries (updated recently in 2025)
- American Samoa,
- Anguilla,
- Fiji,
- Guam,
- Palau,
- Panama,
- Russian Federation,
- Samoa,
- Trinidad & Tobago,
- US Virgin Islands,
- Vanuatu.
Conclusion
Prospective investors, domiciled in tax havens investing 500,000 euros or more in Golden visa investment funds (VC/PE) must carefully evaluate tax consequences before investing. Please seek a professional tax advice before investing.
