The United Arab Emirates is still on Portugal’s list of territories with a clearly more favorable tax regime, as item 22 of Portaria n.º 150/2004. Under Article 16(6) of the Portuguese Personal Income Tax Code (CIRS), a Portuguese national who moves their tax residence to a listed territory is still treated as a Portuguese resident in the year of the move and the following four years, and taxed on worldwide income.

The Portugal to UAE double tax treaty does not rescue them, because its Article 4 treats an individual as a UAE resident only if they are a UAE national. This guide covers the blacklist and the five-year rule, the ordinary residence tests, why the treaty is closed to Portuguese citizens, what Portugal taxes once you are genuinely non-resident, the fiscal representative, and the return regimes, including a trap that can close Programa Regressar to former Dubai residents.

Is the UAE on Portugal’s Tax Haven List? Yes

Portaria n.º 150/2004 of 13 February 2004 lists “22) Emiratos Árabes Unidos” among the countries, territories and regions with clearly more favorable tax regimes. Every later amendment removed other territories and left the UAE entry in place.

Amending instrument What it removed UAE entry
Portaria n.º 292/2011 Cyprus and Luxembourg Unchanged
Portaria n.º 309-A/2020 Andorra, from 1 January 2021 Unchanged
Portaria n.º 292/2025/1 Hong Kong, Liechtenstein and Uruguay, from 1 January 2026 Unchanged

A 2016 portaria that republished the list, still including the UAE, was itself later revoked, and the 2025 portaria describes Portaria n.º 309-A/2020 as the previous update. The Tax Authority (AT) treated the UAE as listed in binding ruling 20912 of 9 November 2023, as reproduced by Lexpoint.

Blacklists are national choices. Spain removed the UAE from its list in 2007, while Italy still presumes its citizens in the UAE are resident, as our guides to Spaniards in the UAE and Italians and the blacklist presumption explain.

The Five-Year Rule in Article 16(6)

Article 16(6) of the CIRS treats as resident “persons of Portuguese nationality who move their tax residence to a country, territory or region with a clearly more favorable tax regime on the list approved by portaria, in the year of the move and the four following years.” A resident is taxed on all income, including income obtained abroad, under Article 15(1).

There are two ways out. The rule does not apply if you prove the move is due to acceptable reasons, the law’s example being temporary work in that territory for an employer domiciled in Portugal, and under Article 16(7) the deemed residence stops in the year you become tax resident in a country that is not on the list.

The rule reaches Portuguese nationals only. A foreign national who has lived in Portugal and moves to Dubai is outside Article 16(6) and is judged under the ordinary tests below.

While the rule applies, a Dubai salary is Portuguese-taxable income with nothing to credit against it, because the UAE levies no personal income tax on salaries. That is the exposure our guide to what a tax-free UAE salary still leaves you owing describes.

The Ordinary Residence Tests

Article 16(1) makes you resident in a year if you stay in Portugal more than 183 days, consecutive or not, in any 12-month period beginning or ending in that year, or if, having stayed less, you have a dwelling in Portugal on any day of that period in conditions suggesting a current intention to keep and occupy it as your habitual residence. Under Article 16(2), any full or partial day that includes an overnight stay in Portugal counts as a day of presence.

Rule What it does to someone leaving for Dubai
Article 16(4) Residence is normally lost from your last day of presence in Portugal, giving a split year
Articles 16(14) and 16(15) You are resident for the whole year of departure if you spent more than 183 days in Portugal that year and earn income after leaving that would have been taxable as a resident, unless that income is taxed abroad at no less than 60 percent of the Portuguese rate, which a tax-free UAE salary can never meet
Article 16(16) If you become resident again in the following year, you are treated as resident for the whole of the year you left

For a Portuguese national going to Dubai, these tests matter mostly for the departure year and for the years after the five-year rule ends. A dwelling kept ready for your use in Lisbon or Porto is enough on its own to make you resident, without any day count.

Why the Portugal to UAE Treaty Does Not Cover You

The Convention between Portugal and the UAE was signed in Abu Dhabi on 17 January 2011, approved by Resolution of the Assembly of the Republic n.º 47/2012 and published in the Diário da República of 13 April 2012. Its Article 4(1)(b) defines a UAE resident as “an individual who has his domicile in the United Arab Emirates and is a national of the United Arab Emirates.”

A Portuguese citizen living in Dubai fails the nationality condition, so they are never a UAE resident under the treaty. The tie-breaker in Article 4(3) can only engage for someone resident in both states, which in practice means a dual Portuguese and Emirati national, and the English text prevails where the language versions differ.

Portugal therefore joins Spain, Poland and the Netherlands in the group of UAE treaties that shut expatriates out, as our guide to Polish tax residency and the nationality clause explains. The treaty’s credit method in Article 23 would give nothing in any case, since there is no UAE income tax to credit.

The practical consequence is that Article 16(6) operates unopposed. A UAE tax residency certificate is still valuable as evidence of where you live, including for the Article 16(7) early exit if you later move elsewhere, but it cannot trigger treaty protection for a Portuguese national.

What Portugal Taxes Once You Are Non-Resident

A non-resident is taxed only on income obtained in Portugal under Article 15(2). Article 18 treats employment income as Portuguese-source not only when the work is done in Portugal but also when it is paid by an entity resident or established in Portugal, so a salary from a Portuguese employer can be Portuguese income even for work done in Dubai.

Portuguese income of a non-resident Treatment CIRS provision
Employment income, business income and pensions 25% final withholding Article 71(4)
Capital income such as interest and dividends 28% final withholding Article 71(1)
Residential rent 25% flat rate Article 72(2)
Non-residential rent 28% flat rate Article 72(1)(e)
Gain on selling Portuguese real estate, from 2023 50% of the gain included, aggregated, taxed at progressive rates set by reference to worldwide income Articles 43(2)(b), 22(3)(a) and 22(10)

Many guides still quote 28 percent on all rent. Since Law 56/2023, residential leases are taxed at 25 percent, with further reductions for long leases, and only non-residential rent stays at 28 percent.

The property sale rule catches Dubai residents in particular. The AT’s Ofício Circulado n.º 20255 of 14 April 2023 confirms that, for gains from 1 January 2023, the progressive rate is set using all income including income obtained outside Portugal, so a tax-free Dubai salary still has to be declared because it pushes up the rate applied to the Portuguese gain. The UAE side of the sale is covered in our guide to capital gains on property for UAE residents.

Fiscal Representative or Electronic Notifications

Article 19(6) of the General Tax Law (LGT) requires taxpayers resident abroad, and residents absent for more than six months, to appoint a representative resident in Portugal. Under Article 19(15), that duty does not apply if you sign up for electronic notifications through the public notification service or the Portal das Finanças.

For someone living outside the EU and EEA, Article 19(16) says cancelling electronic notifications only takes effect once a fiscal representative has been appointed. The government’s announcement of the change applies it expressly to Portuguese citizens resident outside the EU, Norway, Iceland and Liechtenstein.

Two deadlines matter. Article 19(4) says a change of domicile has no effect until it is notified to the Tax Authority, and Article 19(5) requires a change of residence status to be notified within 60 days.

Changing Your Tax Address and Registering at the Embassy

The AT’s frequently asked questions set a 60-day deadline where an address change turns a resident into a non-resident, and accept documents proving residence abroad issued by an official body of the other state or by the Portuguese Embassy or Consulate there. The AT may also ask for a tax residence certificate.

The Embassy of Portugal in Abu Dhabi covers Portuguese residents of the UAE, Kuwait and Iraq and states that no appointment is needed for consular registration alone. Registration is what lets the consular section later issue the proof of residence abroad the AT accepts.

Coming Back: Programa Regressar and IFICI

Article 12-A of the CIRS excludes 50 percent of employment and business income from tax for five years, up to the upper limit of the first bracket in Article 68-A, which is EUR 250,000, for people who become resident by 2026, were not resident in Portugal in any of the five previous years, were resident at some earlier time, and have their tax affairs in order. Anyone who applied for the former non-habitual resident regime is excluded.

Two recent points narrow it further. The AT’s binding ruling 30273 of 23 April 2026 counts the five years as full calendar years in which you were not resident for any part, and the 2026 State Budget Law (Lei n.º 73-A/2025) did not extend the regime beyond 2026 returns.

For a Portuguese national who moved to Dubai, there is a further problem that follows from Article 16(6). Our reading is that years in which the five-year rule made you a deemed Portuguese resident are years of Portuguese residence, so they cannot count toward the five years of non-residence that Article 12-A requires.

The alternative is IFICI under Article 58-A of the Tax Benefits Statute, a 20 percent special rate on net employment and business income for ten consecutive years in qualifying research, innovation and highly qualified roles, with no nationality condition. It also requires five years of non-residence, cannot be combined with Article 12-A, is closed to anyone who benefited from the non-habitual resident regime, and can be used only once.

The Order to Do This In

  1. Assume the five-year rule applies if you are a Portuguese national moving to the UAE, and budget for Portuguese tax on your Dubai salary.
  2. Check whether acceptable reasons apply, such as temporary work for an employer domiciled in Portugal, and keep the evidence.
  3. Plan the departure year around 183 days, because more than that makes you resident for the whole year of departure.
  4. Give up any Portuguese dwelling kept for your own use, or it can make you resident without any day count.
  5. Notify your change of residence within 60 days and sign up for electronic notifications, or appoint a fiscal representative.
  6. Register at the Embassy in Abu Dhabi so it can certify your residence abroad.
  7. If you later move to a country not on the list, document it, because Article 16(7) ends the deemed residence that year.
  8. Before returning, count full calendar years of genuine non-residence before relying on Article 12-A or IFICI.

What We Could Not Verify

The Diário da República’s consolidated version of Portaria n.º 150/2004 could not be rendered, so the UAE’s continued listing rests on the original portaria, the Tax Authority’s copies of each amending portaria and its 2023 binding ruling. We could not read the text of Portaria n.º 292/2011 or the provision that revoked the 2016 portaria.

We could not confirm the treaty’s date of entry into force from a primary source; secondary sources give 22 May 2012. We did not check whether the treaty is modified by the OECD Multilateral Instrument.

The CIRS applies 35 percent rates to certain income of non-resident “entities” domiciled in listed territories, and we found no primary source confirming whether those rates reach individuals living in the UAE, so we have not stated them. The conclusion that deemed residence under Article 16(6) blocks Article 12-A is our reading of the two provisions, not a published AT position.

Frequently Asked Questions

Is the UAE on Portugal’s tax haven blacklist?

Yes. The United Arab Emirates is item 22 of Portaria n.º 150/2004, and none of the amendments, including Portaria n.º 292/2025/1 which removed Hong Kong, Liechtenstein and Uruguay from 2026, has removed it. The Tax Authority treated the UAE as listed in a binding ruling of November 2023.

If I move from Portugal to Dubai, do I still pay IRS in Portugal?

If you are a Portuguese national, generally yes for five years. Article 16(6) of the CIRS keeps Portuguese nationals who move to a listed territory resident in the year of the move and the following four years, taxed on worldwide income, unless they prove acceptable reasons for the move.

How does the five-year rule end early?

Under Article 16(7), the deemed residence stops in the year you become tax resident in a country, territory or region that is not on the list. It also does not apply at all if you prove the move to the UAE was for acceptable reasons, such as temporary work for an employer domiciled in Portugal.

Does the Portugal to UAE treaty protect Portuguese citizens living in Dubai?

No. Article 4(1)(b) of the convention signed on 17 January 2011 treats an individual as a UAE resident only if they are domiciled in the UAE and are a UAE national. A Portuguese citizen cannot be a UAE treaty resident, so the tie-breaker never applies.

How many days can I spend in Portugal without becoming tax resident?

Up to 183 days in any 12-month period beginning or ending in the year, counting any day that includes an overnight stay, and only if you do not have a dwelling in Portugal kept for use as your habitual residence. For Portuguese nationals in the UAE, the five-year rule applies on top of these tests.

What happens in the year I leave Portugal?

Residence normally ends on your last day in Portugal, but under Articles 16(14) and 16(15) you are resident for the whole year if you spent more than 183 days in Portugal that year and later income would have been taxable as a resident. The exception requires that income to be taxed abroad at 60 percent or more of the Portuguese rate, which a UAE salary never meets.

Do I need a fiscal representative in Portugal if I live in the UAE?

Article 19(6) of the General Tax Law requires one for taxpayers resident abroad, but Article 19(15) removes the duty if you sign up for electronic notifications. If you live outside the EU and EEA, you cannot cancel electronic notifications until you have appointed a representative.

How is rent from my Portuguese apartment taxed if I live in Dubai?

Residential rent is taxed at a flat 25 percent under Article 72(2) of the CIRS, with lower rates for long leases, while non-residential rent is taxed at 28 percent. If the five-year rule still makes you resident, the rent is taxed as part of your resident income instead.

How much tax do non-residents pay when selling property in Portugal?

Since 1 January 2023, 50 percent of the gain is included and taxed at the progressive rates, with the rate set by reference to all your income including income obtained abroad. The Tax Authority’s Ofício Circulado 20255/2023 confirms that worldwide income, such as a Dubai salary, must be taken into account to set the rate.

Can I use Programa Regressar when I return from Dubai?

Only if you become resident by 2026, were not resident in Portugal in any of the five previous full calendar years, were resident at some earlier time and have your tax affairs in order. Years in which the five-year rule made you a deemed resident are, on our reading, years of residence, which can make a Dubai returner ineligible.

Does IFICI apply to Portuguese citizens returning from the UAE?

It can. Article 58-A of the Tax Benefits Statute has no nationality condition and gives a 20 percent special rate for ten years in qualifying research, innovation and highly qualified roles, but it requires five years of non-residence, excludes former non-habitual residents and anyone using Article 12-A, and can be used only once.

Do I have to register at the Portuguese Embassy in the UAE?

The Embassy of Portugal in Abu Dhabi asks Portuguese residents of the UAE to register and says no appointment is needed for registration alone. The Tax Authority accepts proof of residence abroad issued by the Embassy or Consulate when you change your tax residence status.

Official Sources

Information current as of September 2026. Portugal’s list of territories with more favorable tax regimes is amended periodically, residence depends on your own facts, and the Programa Regressar window closes with 2026. This guide is for informational purposes only; confirm your position with the Autoridade Tributária e Aduaneira or a qualified Portuguese tax adviser before relying on any treatment described here.