Key figures — as of 2026-08-21: Cabinet has a 180-day window from Lei n.º 9-A/2026 (signed 2 March 2026) to issue implementing decrees, expiring early September 2026 — Investment Contracts for Letting (CIA) and the Simplified Affordable Letting Regime (RSAA) are already scheduled to enter into force on 1 September 2026; VAT on qualifying construction/renovation drops from 23% to 6% for homes up to €660,982 or rentals up to €2,300/month; self-builders can claim a partial VAT refund on projects started between 25 September 2025 and 31 December 2029.
Why the September date matters
The number that counts here isn't a tax rate — it's a countdown. The law grants the government until early September 2026 to issue the necessary decrees, including defining the exact parameters of the CIA contracts, establishing the VAT refund mechanism for self-builders, and creating the simplified rental regime. Miss it, and the process doesn't simply slip — delays beyond that window would require fresh parliamentary authorization.
For foreigners building a home, buying into a rental-investment structure, or weighing a self-build project, this is the difference between a usable scheme and a headline promise. The framework law — Lei n.º 9-A/2026, approved by lawmakers on February 20 and signed into force by the President on March 2 — set the direction. The detail arrives (or doesn't) in the coming weeks.
What's already locked in — and what isn't
The base legislation, Decree-Law no. 97/2026, published on 20 May 2026, approves a set of tax relief measures amending the VAT Code, IRS, IRC, IMT Code, and the Tax Benefits Statute, alongside the CIA regime, the RSAA, and a regime for partial restitution of VAT on construction for owner-occupied housing. Several headline dates are fixed: the CIA regime enters into force on 1 September 2026, with contracts signed between investors and the Institute for Housing and Urban Rehabilitation (IHRU).
To qualify, investments must meet two cumulative requirements: at least 70% of the construction area allocated to residential letting, and monthly rent capped at €2,300 (moderate rent). The RSAA runs on a parallel track: eligible agreements must keep rents at or below 80% of the median published by the National Statistics Institute (INE), with a minimum three-year term for permanent residence contracts (three months for temporary residence). In return, landlords get full exemption from personal and corporate income tax on rental income under these agreements.
The gap: nobody yet knows the exact municipal figures that will define "moderate rent" in practice. One legal breakdown of the decree notes that RSAA rent limits are not to exceed 80% of the median rent per sqm in the relevant municipality, to be set by ministerial order — an order that hasn't been published. Until it is, landlords weighing whether to opt into RSAA are essentially guessing at their own rent ceiling.
The self-build VAT refund — what it could actually be worth
For owner-builders, the reduced 6% VAT rate on construction and renovation already applies on paper, but the refund mechanism for people who paid the standard 23% before the scheme kicked in is still being written. Individuals building their own permanent home can obtain a refund of the difference between VAT paid at the standard rate and what would have resulted from the reduced rate, provided the property doesn't exceed the moderate value limits. That window covers projects carried out between 25 September 2025 and 31 December 2029, with VAT chargeable up to 31 December 2032.
Here's GrowIN's own math: on a self-build with €150,000 in eligible construction costs, the 17-point gap between the 23% standard rate and the 6% reduced rate works out to roughly €25,500 in potential VAT recovery — money that stays locked up until the Finanças issues the actual claim procedure, likely a formal request through Portal das Finanças once the implementing order lands.
"A tax cut that exists only in the decree, not in the claim form, doesn't put a euro back in anyone's account," is how GrowIN Portugal Editorial sums up the current limbo.
What foreign buyers should watch
Non-resident buyers should keep separate track of the unrelated but simultaneous change: 7.5% now applies as the flat IMT transfer tax rate on residential purchases by non-residents, a cost that sits outside this September deadline but compounds the calculation for anyone weighing a rental-investment property purchase this autumn. Anyone structuring a purchase or self-build should treat announced rates as directional until the ministerial orders on rent ceilings, refund procedures and CIA contract templates are published — expect movement from the Ministries of Finance and Infrastructure/Housing through late August and into September. Our tax & NIF guide tracks the VAT and IMT mechanics as the paperwork firms up.
Outcomes here depend entirely on what Lisbon actually publishes before the clock runs out — buyers and self-builders should treat every figure above as provisional until the implementing decrees appear in Diário da República.
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