Portugal: Disclosure of Offshore Assets

With the entry into force of Decree-Law No. 13/2025 of 6 March, individuals who are tax residents of Portugal are now subject to additional reporting obligations in their annual tax returns regarding assets located in countries, territories, or regions with clearly more favourable tax regimes.

Who is required to disclose such assets?

Individuals who are liable to personal income tax (IRS) in Portugal.

In which return must the assets be declared?

The assets must be reported in the Personal Income Tax Return (Modelo 3 IRS).

What types of assets are subject to disclosure?

Assets owned by the taxpayer and located in jurisdictions with clearly more favourable tax regimes.

The official list of such jurisdictions can be found via the link provided. Notably, this list includes the UAE, Jordan, Vanuatu, Grenada, Jamaica, among others.

Types of assets to be declared include

• Property rights over real estate situated in any of the listed jurisdictions;
• Cars, boats or aircraft registered in those countries;
• Securities held in deposit or securities accounts with entities that have their registered office or domicile in such jurisdictions, or in branches located therein;
• Shares, equity interests or units in companies domiciled or registered in those jurisdictions;
• Units and similar instruments in collective investment undertakings (CIUs), alternative investment funds (AIFs), or venture capital funds managed or administered by entities domiciled or headquartered in those jurisdictions, or by branches thereof;
• Bonds and other debt securities issued by entities domiciled or headquartered in such jurisdictions;
• Shareholder loans and other forms of financing provided to entities domiciled or headquartered in those jurisdictions or to their branches;
• Insurance policies or annuity contracts entered into with entities registered or operating in those jurisdictions or their branches;
• Assets or securities held in partnerships and fiduciary structures where the beneficiary is a company incorporated in those jurisdictions, or managed/administered by entities domiciled or operating there.

These developments reflect Portugal’s increasing scrutiny of taxpayer assets held in offshore jurisdictions. This shift appears to align with the government’s broader objective of ensuring greater transparency within the tax system, preventing tax evasion, and improving the administration of tax liabilities.

In our view, such measures may also be linked to the application of Portugal’s Controlled Foreign Company (CFC) rules, which aim to curb capital flight to low-tax jurisdictions and encourage taxpayers to disclose foreign assets more transparently.

Author: Yaroslavna Zadesenskaya

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