Newsletter #11

|01/27/2025|

Dear Customers and Friends,

First of all, we wish you all an excellent 2025, full of success and achievements. It is with great pleasure that we launch another edition of our newsletter, where we highlight topics that we consider fundamental for your planning and decision-making in this new year.

In this publication, we share the main points of the State Budget for 2025 , compiled by the Portuguese Association of Certified Accountants, with a focus on tax changes and support measures for companies and citizens. We also highlight the Agenda for Tax Simplification , which promises to transform the relationship between taxpayers and the Tax Authority, making it more efficient and transparent.

Finally, we explore the tax neutrality regime , clarifying its frameworks, limitations and practical applications, an increasingly relevant topic in the context of corporate reorganizations.

We hope this newsletter will be a useful tool to keep you informed and prepared for the challenges of 2025.

With best regards,

Jose Antonio Marques Pereira
Partner
Edgar Torrao
Partner
marques.pereira@marquespereira.pt
Tel.: + 351 92 627 4049
edgar.torrao@marquespereira.pt
Tel.: + 351 91 758 40 68

#1 - Tax Arbitration - IRS - Exchange of shares - Fiscal Neutrality

CAAD, Process No. 189/2024-T

The Administrative Arbitration Center (CAAD) recently ruled on a case related to the tax neutrality regime applied to an exchange of shares.

#2 - Reinvestment of real estate capital gains in financial products - Eligibility for life insurance contracts

Binding Information from AT, Process No. 23902

The Tax Authority has issued a doctrinal document related to the reinvestment of real estate capital gains in life insurance contracts.

#3 - Simple spin-off operation with separation of a line of business into a new company - tax neutrality regime

Binding Information of the AT, Process No. 26255

The document deals with the acceptance of invoices in PDF format as a valid support for VAT deduction until December 31, 2024, in accordance with article 284 of the State Budget Law for 2024 (Law no. 82/2023). This measure was extended until December 31, 2025, in accordance with the 2025 State Budget.