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Nuno de Oliveira Garcia clarifies issues regarding the issuance of IMI settlement notes | CNN
Nuno de Oliveira Garcia, partner and head of Tax, advises that, given the delay in the arrival of settlement notices at people’s homes this year, the references provided on the Finance Portal should be used, as it is not possible to know ‘when the letter will arrive’, in a CNN Portugal article.
Technical constraints following the ‘blackout’ on 29 April delayed the sending of IMI settlement notices, with the Government deciding to extend the payment deadline for this tax (for the first instalment or the single instalment for amounts up to €100) until the end of June, i.e. for one month longer than usual.
In this context, Nuno de Oliveira Garcia’s advice is that people sign up to Via CTT, so that they receive notifications and settlement notices electronically only.
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Sandra Cuesta
Director of Business Development, Marketing and Communications
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Tax measures contained in Royal Decree-law 7/2026 approving the Comprehensive Plan to Address the Crisis in the Middle East
The package of tax measures included in Royal Decree-law 7/2026, of 20 March, consists of various incentives in the field of direct taxation of individuals and companies to reduce dependence and promote energy savings and efficiency, electric mobility, and support for self-consumption and investment in renewables. Moreover, it includes a set of extraordinary and temporary measures applicable to energy taxation and indirect taxation aimed at reducing the tax burden on products particularly affected by rising prices. Lastly, certain changes are made to various local taxes.
PUBLICATION
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Belgium in breach of Anti-Tax Avoidance Directive by denying taxpayers the deduction of corporate income tax paid by controlled foreign companies
In its Judgment of 26 February 2026, in Case C-524/23, the Court of Justice of the European Union has ruled that the Kingdom of Belgium has failed to fulfil its obligations under Directive (EU) 2016/1164, by failing to adopt the statutory, regulatory and administrative provisions necessary to ensure taxpayers’ right to a deduction of the tax paid by controlled foreign companies from the corporate income tax liability of the taxpayer.
PUBLICATION
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Family-owned businesses: Subsidiaries engaged in real estate leasing are not required to hire an employee if structurally part of a corporate group’s business activity
The Supreme Court rules that the requirement of having at least one full-time employee for an undertaking engaged in real estate leasing to be regarded as carrying on business may be deemed fulfilled by way of an associated company when such is functionally part and parcel of the business activity of the group of companies as a whole.
PUBLICATION
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Highlights of the OECD Model Tax Convention on Income and on Capital update
The new update to the OECD Model Tax Convention on Income and on Capital incorporates regulatory adjustments, interpretative clarifications and additional criteria in response to recent developments in international taxation. It addresses relevant issues relating, among other things, cross-border teleworking, the exploration and exploitation of natural resources, transfer pricing aspects of financial transactions or information received through exchange of information.
PUBLICATION
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New audit actions linked to advanced cooperation mechanisms in tax matters: special reference to ‘joint audits’
Recently, the Tax Agency’s departments have been altered in order to, among other things, adapt their roles and responsibilities to new forms of tax-related administrative cooperation —covered by Council Directive (EU) 2021/514 (DAC7) and transposed into the Taxation Act —. Among these, we highlight in this commentary the importance of joint audits, recalling their main characteristics and analysing some of the problems that their implementation may pose
PUBLICATION
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Non-resident taxpayers may benefit from the wealth tax liability cap
All taxpayers subject to wealth tax, both residents and non-residents, are in a comparable situation and must therefore be able to apply the combined cap of Article 31(1) LIP, the existence of a real or personal obligation being irrelevant for the purposes of the comparability analysis, since the determining factor is the nature and purpose of this tax device, as well as its content.
PUBLICATION
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Danish cases in Spain: Beneficial owner requirement not applicable to the non-resident income tax exemption of interest payments to EU residents
Contrary to the stance taken by the Audiencia Nacional, the Valencia High Court of Justice takes the view that the exemption of interest payments to European Union residents should be applied in accordance with the terms that the national legislature has chosen to keep, without the additional requirements of Directive 2003/49/EC. If abusive practices are found to exist, tax regularisation must be carried out by resorting to one of the general anti-abuse clauses provided for in the Taxation Act.
PUBLICATION
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Property Transfer Tax in assignment of promissory contracts to sell real estate in Portugal
This article analyses situations which, although they do not involve the transfer of property ownership, are legally treated as equivalent to a sale and are subject to Transfer Tax in Portugal.
PUBLICATION
15 Jul, 2025
The Court of Justice upholds the annulment of the European Commission's third decision on the scheme for the tax amortisation of financial goodwill
La Sentencia del Tribunal de Justicia de 26 de junio del 2025 declara que las dos primeras decisiones de la Comisión Europea sobre la incompatibilidad con las normas sobre ayudas estatales del régimen de amortización fiscal del fondo de comercio financiero generaron confianza legítima sobre el alcance y límites de la obligación de recuperación, incluyendo dentro de su alcance las adquisiciones directas e indirectas de participaciones en empresas extranjeras. Por tanto, no cabe la recuperación retroactiva de las ayudas relacionadas con adquisiciones indirectas cubiertas por las dos primeras decisiones, por lo que debe procederse a su devolución junto con los intereses de demora.