Does the CIA apply to buying a single apartment?

No: it is a project regime (construction/rehabilitation) conditioned on committing at least 70% of floor area to moderate rentals. A private landlord looks to 45.º-C (10%) or the RSAA instead.

Can the IMT refund be combined with the rental regimes?

That is the decree-law's very architecture: moderate-rent commitment opens both the non-resident IMT surcharge refund and the income regimes (10% or RSAA exemption), each under its own conditions.

Portugal's CIA & RSAA (DL 97/2026): 6% VAT, IMT/IMI/AIMI exemptions for moderate rentals

CIA and RSAA: the investor side of Decree-Law 97/2026

After the 7.5% IMT stick, the carrot: the same decree-law pays — in VAT and exemptions — projects committing floor area to moderate rents. Provided you hold the 70% threshold.

1 September 20264 min readLa rédaction — Wealth Management · Global Real AssetsPortugalFacts checked on 1 September 2026Subject to regulatory updates

Key points

Decree-Law 97/2026 does more than tax non-resident acquisitions: its rental incentives entered into force on 1 September 2026.
The Rental Investment Contract (CIA) opens a reduced 6% VAT on construction and IMT, IMI and AIMI exemptions to projects committing at least 70% of floor area to moderate-rent housing.
The RSAA regime (affordable housing simplification) exempts rental income from IRS and IRC for landlords observing the rent caps.
The moderate-rent reference cap remains 2.5× the minimum wage (around EUR 2,300/month in 2026) — the same template as the 10% autonomous tax of article 45.º-C, covered in our dedicated text on the private-landlord side.
On the tenant side, the annual IRS rent deduction rises to EUR 1,000 from 2027 — solvent-demand support that indirectly de-risks the conventioned landlord.
The bricks assemble: 7.5% IMT refundable through rental commitment, income at 10% or exempt, 6% construction VAT — one building can stack several regimes, provided it is structured for it.

The CIA: a contract, not a counter

The benefit does not fall out of zoning: it is contracted. The sponsor commits — floor areas, caps, duration — and the State pays in VAT and duties. The 70% committed-area floor is the regime's lock: a mixed project slipping under the threshold loses the exemption block. In a development SPV, that constraint is handled upstream, in the plan and the contract — not at permit time.

RSAA: exemption in exchange for discipline

Exempting IRS and IRC on capped rents inverts the classic computation: headline yield falls, net yield climbs. In the mid segment — where market rent flirts with EUR 2,300 — the net gap between a free lease taxed at scale and a conventioned exempt lease can surprise. It is a computation, not a slogan; we run it deal by deal.

Our reading

Portugal in 2026 draws a coherent policy: pricing up passive acquisition (7.5% IMT), paying for disciplined rental supply (CIA, RSAA, 45.º-C). For a structured investor, the second column funds the first — the same decree-law contains the cost and its antidote. Few statutes offer arithmetic this legible; part of it expires at end-2029, which dates the opportunity. That framework — entry cost, contracted antidotes — is priced into the file we are reviewing in the Algarve.

General information, verified at publication date. Tax law evolves: every transaction calls for licensed advice.

Journal articles are published for general, educational purposes. They constitute neither legal, tax or financial advice, nor an offer. Every situation calls for the analysis of licensed advisers.