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Nuno Oliveira Garcia analyses new Tax Authority rules for the valuation of wind and solar farms | Jornal de Negócios
19 August, 2026
Nuno Oliveira Garcia highlights that the Portuguese Tax Authority’s new guidance on the valuation of wind and solar farms represents a significant shift in the interpretation of the concept of “property” for IMI (Municipal Property Tax) purposes, by treating renewable energy generation facilities as a single economic unit comprising a universal set of assets.
He notes that the new circular requires the inclusion of the equipment and infrastructure necessary for the conversion of renewable energy into electricity in the property valuation process, following recent Supreme Administrative Court case law and seeking to bring an end to a long-standing dispute between the tax authorities and operators in the renewable energy sector.
According to his analysis, this change may lead to an increase in the taxable property value of wind and solar installations and, consequently, in the amount of IMI payable by the owners or operators of these facilities, although the actual impact will depend on the characteristics of each individual project.
Finally, he warns of the economic and tax implications of this new interpretation, which has already been challenged by stakeholders in the renewable energy industry, and stresses the importance of monitoring future legislative and judicial developments in this area, given their relevance to investors and to the municipalities where these projects are located.
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Highlights of the OECD Model Tax Convention on Income and on Capital update
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