The memo summarizes recent changes to Portuguese tax law introducing the concept of trusts. Payments from trust structures will now be considered "Category E income" taxed at 28%, or 35% if from a blacklisted jurisdiction. Amounts received by the settlor from dissolving a trust will be taxed as capital gains. Beneficiaries receiving assets from a dissolved trust will pay a 10% flat gift tax if the assets originated in Portugal. Trust income may not qualify for the non-habitual resident tax exemption due to lack of double taxation agreements covering trusts.