Summary
Full Decision
ARBITRAL DECISION
CAAD: Tax Arbitration
Case No. 113/2014 – T
Subject Matter: IUC – Subjective incidence; absolute incompetence of the Tribunal in respect of subject matter.
I – REPORT
A) The Parties and Constitution of the Arbitral Tribunal
"a" – Financial Credit Institution, SA, Tax Identification Number .., with registered address at Street …, Plot…, in Lisbon, hereinafter referred to as "Applicant", requested the constitution of a singular Arbitral Tribunal, under the provisions of articles 2, No. 1, subparagraph a) and 10, Nos 1 and 2 of Decree-Law No. 10/2011, of 20 January, hereinafter referred to as "RJAT" and of Ordinance No. 112 – A/2011, of 22 March, seeking the declaration of illegality of the assessments of Unique Circulation Tax (IUC) relating to the tax periods of 2009, 2010, 2011 and 2012, attached to the case file as documents Nos 2 to 77 and which are considered fully reproduced herein, in the total amount payable of €6,392.24. The Applicant further seeks recognition of the right to reimbursement of the amount of tax improperly paid as well as the right to indemnity interest, calculated on the said amount of tax paid.
The request for constitution of the Arbitral Tribunal was presented by the Applicant on 12 February 2012, was accepted by the Honorable President of CAAD and notified to the Tax and Customs Authority.
The Applicant opted not to designate an arbitrator, whereby, under the provisions of No. 1 of article 6 of the RJAT, the undersigned was designated by the Deontological Council of the Administrative Arbitration Centre as singular arbitrator. The appointment was accepted and the parties were notified of the arbitrator's designation, neither having expressed the intention to refuse the appointment.
Thus, in accordance with the provisions of subparagraph c), of No. 1, of article 11, of Decree-Law No. 10/2011, of 20 January, as amended by article 228 of Law No. 66-B/2012, of 31 December (RJAT), the Singular Arbitral Tribunal was constituted on 15 April 2014. On the same date, the Tax Authority was notified, under the terms and for the purposes of the provisions of Nos 1 and 2 of article 17 of the RJAT, to present its reply within the legal time period.
The Tax Authority presented its reply on 21 May 2014, which is considered fully reproduced herein. On 5 June 2014, the Applicant presented a request for a reply to the exceptions raised by the Tax Authority, in relation to which the latter commented, by request of 11 June 2014, which are considered fully reproduced herein.
On 17 June 2014, the meeting provided for in article 18 of the RJAT took place, with the parties presenting their oral submissions, as evidenced by the minutes attached to the case file and which are hereby considered fully reproduced. It was determined that the Arbitral Decision would be rendered by 31 July 2014.
B) THE REQUEST FORMULATED BY THE APPLICANT
The Applicant formulates the present request for arbitral determination, seeking the illegality, with consequent annulment, of the assessments of Unique Circulation Tax and respective Compensatory Interest, relating to the tax periods of 2009, 2010, 2011 and 2012, embodied in the documents attached to the case file as documents Nos 2 to 77, referred to by the Applicant as official assessments of IUC.
In summary, it bases its request, alleging as follows:
a) Within the scope of its activity, the Applicant enters into long-term rental contracts and financial leasing contracts for motor vehicles with its clients, at the end of which it transfers ownership of the same to the respective lessees or to third parties;
b) Between 14 November 2013 and 20 December 2013, the Applicant was notified of official assessments of IUC relating to the vehicles identified in the request for arbitral determination (summary table attached as document No. 1 and documents Nos 2 to 77) and to the tax periods 2009, 2010, 2011 and 2012;
c) The Applicant proceeded with voluntary payment of the IUC allegedly in arrears. Despite this, the Applicant cannot fail to manifest its disagreement with respect to the said assessment acts, insofar as the vehicles in respect of which the payment of IUC was incumbent were not its property on the date identified by the Tax Authority as the date of the occurrence of the taxable event;
d) Under the provisions of article 3, No. 1 and article 6 of the IUC Code, the legal system in force, resorting to the registration element, establishes, simultaneously, the taxable event of the tax and the respective fiscal connection;
e) Article 3 of the IUC Code enshrines a norm of subjective incidence which establishes, merely, a legal presumption, all the more so as in the tax legal system we can find the verb "to be considered" used with a presumptive sense;
f) It is, therefore, a presumption, whose rebuttal is permitted by article 73 of the General Tax Law; the Applicant indicates, in this regard, several examples extracted from the legal system in force;
g) It further invokes, in defence of its thesis, the principle of equivalence, provided for in article 1 of the IUC Code, under the terms of which the tax should burden the taxpayers to the extent of the environmental and road cost that they cause in the implementation of a general rule of tax equality;
h) It further concludes, in light of the interpretative elements extracted from the purposes revealed in Bill No. 118/X, and, as well, of the rational element underlying the reform of motor vehicle taxation, that this is a structuring principle of the IUC;
i) Thus, the liable persons of this tax are only the owners or equivalent of the vehicles, in whose names the same are registered, that is to say their "actual owners";
j) The Applicant alleges that presumptions of incidence can be rebutted through the procedure provided for in article 64 of the Code of Administrative Tax Procedure or, alternatively, by means of administrative complaint or judicial challenge of the tax acts based on them;
k) In that measure, and in order to rebut the presumption arising from the registration of the motor vehicle, the Applicant presented copies of invoices/receipts of sales, which it attached as documents Nos 78 to 133;
l) It thus concludes that on the date of the exigibility of the tax to which the assessments in question relate, it was not the Applicant (RCI Gest IFIC) who was the owner of the vehicles identified therein, as their respective transfers had already previously taken place, under the terms of civil law, in accordance with the principles enshrined in articles 874, 879 and 408 of the Civil Code (CC);
m) It further adds that, if it is true that article 5 of Decree-Law No. 54/75 of 12 February provides that the right of property in motor vehicles is subject to registration, from the same diploma it follows that registration essentially aims to give publicity to the legal situation of vehicles (…) and, being silent as to the legal value of motor vehicle property registration, its article 29 remits to the application of the provisions relating to property registration;
n) Article 7 of the Property Registration Code provides that definitive registration constitutes a presumption that the right exists and belongs to the registered holder, in the precise terms in which the registration defines it;
o) This presumption can be rebutted by the presentation of proof to the contrary, such as that which the Applicant presents in the present case file;
p) As the Tax Authority does not meet the requirements of the notion of "third party" for purposes of registration, it cannot avail itself of the absence of updating of the registration of the right of property to call into question the full efficacy of the purchase and sale contract and to require the seller (former owner) to pay the IUC due by the buyer (new owner), provided that the presumption of the respective ownership is rebutted;
q) It concludes by petitioning for the declaration of illegality of these IUC assessments, in the total amount of €6,392.24, recognition of the right to reimbursement of the value of tax already paid, as well as the right to indemnity interest for the payment of tax improperly assessed.
C – THE RESPONDENT'S REPLY
The Respondent, duly notified to this effect, timely presented its reply in which it alleged, in summary, as follows:
a) By way of exception:
aa) Lack of subject matter and incompetence of the Arbitral Tribunal in respect of subject matter;
bb) Omission of prior Administrative Complaint.
b) By way of challenge:
aa) The Tax Authority alleges that the Applicant is not right as to the invoked error regarding the assumptions, given that the interpretation advocated by the Applicant not only incurs a skewed reading of the letter of the law, but also the adoption of an interpretation that does not regard the systematic element, violating the unity of the system enshrined in the entire IUC Code and, more broadly, in the entire legal-fiscal system and further results from an interpretation that ignores the rationale of the system enshrined in the article in question, and as well, in the entire IUC Code;
bb) It bases its allegation on the provisions of Nos 1 and 2 of article 3 of the IUC Code;
cc) The Tax Authority further alleges that the legislator did not use the expression "are presumed", as it could have done, indeed in a manner similar to what occurs in other legal provisions, exemplifying some situations provided for in the law;
dd) It understands, therefore, that in cases where the tax legislator uses the expression "are considered", it is not establishing a presumption;
ee) To understand that the legislator established here a presumption would unequivocally be to carry out an interpretation against the law;
ff) It concludes, therefore, that in the case of the present case file, the legislator expressly and intentionally established that those in whose names the same are registered are to be considered as such, since this is the interpretation that preserves the unity of the tax legal system;
gg) Any other interpretation would be to ignore the teleological element of interpretation of the law: the rationale of the system enshrined in the article in question, and as well, in the entire IUC Code;
hh) It reinforces this allegation by invoking that this is the interpretation followed by the case law of our courts expressed in the judgment rendered by the Administrative and Tax Court of Penafiel, within the scope of Case No. 210/13.0BEPNF;
ii) It concludes that article 3 of the IUC Code contains no legal presumption whatsoever, and for the dismissal of the arbitral request, insofar as the tax acts in issue do not suffer from any defect violating the law, insofar as in light of the provisions of article 3, Nos 1 and 2 of the IUC Code and article 6 of the same code, the Applicant, in the capacity of owner, was the liable person of the IUC, as attested by the Information relating to the history of ownership of the vehicles in question, issued by the Motor Vehicle Registration Office;
jj) In the Tax Authority's view, it is undeniable that the Property Registration Code applies subsidiarily to the Motor Vehicle Registration Regulations, however, the Property Registration Code is not subsidiary legislation to the IUC Code;
kk) The IUC became, under the provisions of article 3 of the IUC Code, due by persons appearing in the registration as owners of the vehicles;
ll) Any other interpretation would be to ignore the teleological element of interpretation of the law; it would, moreover, be an interpretation not in conformity with the Constitution, by violation of the principle of trust and legal certainty, the principle of efficiency of the tax system and the principle of proportionality;
mm) Finally, it further alleges that even if that is not the case, it will be important to assess the probative documents submitted by the Applicant, and their probative value, with a view to rebutting the presumption, concluding that the documents submitted by the Applicant (55 invoices contained in the case file as documents Nos 78 to 133 attached to the Reply) "do not constitute sufficient proof to undermine the supposed legal presumption established in article 3 of the IUC Code, insofar as an invoice is not a document capable of proving the conclusion of a bilateral purchase and sale contract, as that document does not by itself reveal an indispensable and unequivocal declaration of will (i.e. of acceptance) on the part of the alleged purchaser";
nn) The elements of proof brought by the Applicant are incapable of demonstrating the facts alleged, in particular for the purposes of rebutting the legal presumption;
oo) In consequence it concludes, once again, for the dismissal of the arbitral request, as well as of the claim for interest, invoking as to these the non-existence of any error imputable to the services that, in any case, would sustain such condemnation.
D. REPLY TO THE EXCEPTIONS
The Applicant presented, on 5 June 2014, a request for reply to the exceptions raised by the Tax Authority, in which it alleged, in summary, that it was confronted in its private section of the Tax Portal with a series of IUC debts, documented in what the Tax Authority calls collection notes (collection documents). For the purposes of its tax situation, the IUC debts documented by the said collection notes were already subject to payment, and were paid by the Applicant as evidenced by the documentation attached to the request for constitution of Arbitral Tribunal.
It was a priority for the Applicant to proceed with the payment of those IUC debts appearing in the system, since the harm resulting from the impossibility of obtaining, for the most varied purposes of its commercial activity, a negative debt certificate (regularized contribution status certificate), far exceeded the harm from the concrete tax assessments, presupposed in those debts and which are logically antecedent to them. "As for the rest, the Applicant does not know, has no way of knowing. And it finds it highly concerning that the Tax Authority, with respect to a plurality of situations of debts in respect of IUC of which the Applicant was unaware and did not create, contained in the Tax Authority's IT system at a stage that allowed and allows their payment, now comes to say that it has nothing to do with it, and that it would have been the Applicant who was responsible for the generation of the collection notes, whatever exactly that may mean."
The IUC debts contained in the Tax Authority's IT system (in the area of reserved access for the Applicant), are an undeniable fact of the Tax Authority's creation, the possibility of their payment is also an undeniable fact of the Tax Authority's responsibility, and the quantification of their concrete amounts, year and vehicle registration of the tax, is also entirely the responsibility of the Tax Authority and its IT system. These IUC debts presuppose a series of IUC assessments, being irrelevant for the case the manner in which the Applicant became aware of them and the fact is that it reacted against them via a request for constitution of Arbitral Tribunal.
Finally, the Applicant further notes that it paid the IUC debts in December 2013 and, as of the date hereof (June 2014), has not yet been directly notified or ex officio of the assessments. It invokes that this situation is occurring with other taxpayers, which reveals "grave conduct on the part of the Tax Authority: it places the IUC debts visible to taxpayers in their respective reserved areas of the Tax Portal; these come to pay to avoid being prevented from obtaining negative debt certificates essential for the most varied purposes (or to avoid, in particular at the end of the fiscal year, seeing the tax benefits they are enjoying impaired, for example); payment made, the Tax Authority considers the matter closed and does not notify or make known via the Tax Portal (reserved area) anything further; and then comes to invoke that there is no assessment (which in itself is a logical impossibility) subject to being discussed in Court." This appears to be animated by the purest bad faith.
Finally, it further invokes that, should it be concluded that there was collection of an amount as IUC for a given year and with reference to a given vehicle registration, in a scenario of absence of tax assessment logically and legally presupposed in that collection, one would then be faced with the criminal offense provided for in article 379 of the Criminal Code – aggravated by the fact that to date there is no sign of the slightest intention on the part of the Tax Authority to return the amounts received from the Applicant – and a certificate should be extracted from these case files for transmission to the Public Prosecutor's Office so that the competent criminal proceedings may be initiated.
The Tax Authority commented by Request of 11 June 2014, alleging that the RJAT does not provide for the figure of Reply, whereby, having the Applicant presented a reply in writing to the exceptions and this being accepted, then the possibility of commenting thereon subsequently would be ruled out, in particular at the meeting to which article 18 refers.
On the same date of 11 June 2014, an arbitral order was issued admitting the reply to the exceptions and the joinder to the case file of the Tax Authority's request for reply and the parties were invited to comment on the possible dispensation of holding the meeting provided for in article 18, proceeding immediately to final decision or maintaining the meeting or, alternatively, setting a deadline for written submissions. The Tax Authority commented, understanding that the scheduled meeting should be maintained.
In accordance therewith, the meeting referred to in article 18 was held, at which the parties produced their respective oral submissions, regarding the remaining matter in discussion in the case file, having, in summary, both, considered fully reproduced all that was already contained in their respective pleadings attached to the case file.
By request of 21 July 2014, the Tax Authority came, under the principles of collaboration and justice, to request the joinder to the case file of the arbitral decision rendered within the scope of case No. 183/2014 – T, as it concerns the same subject matter in discussion in the present case file.
II - PROCEDURAL PREREQUISITES
The Arbitral Tribunal is regularly constituted. It is materially competent, under the terms of article 2, No. 1, subparagraph a) of Decree-Law No. 10/2011, of 20 January.
The Parties enjoy legal personality and capacity, are legitimate and are legally represented (See article 4 and 10 No. 2 of Decree-Law No. 10/2011 and article 1 of Ordinance No. 112/2011, of 22 March).
The case does not suffer from defects that would invalidate it.
Taking into account the administrative tax proceedings, the documentary evidence attached to the case file, it is now appropriate to present the factual matter relevant to the understanding of the decision, which is established as follows.
III - FACTUAL FINDINGS
A) Established Facts
As relevant factual matter, the present tribunal considers the following facts established:
a) The Applicant, between 14 November 2013 and 20 December 2013, proceeded with voluntary payment of Unique Circulation Tax, considered by the Tax Authority as being in arrears, relating to the tax periods 2009, 2010, 2011 and 2012 and to the vehicles identified in documents Nos 2 to 77 attached in annex to the arbitral request, which are hereby considered fully reproduced.
b) To proceed with this payment, the Applicant issued the IUC assessments, contained in the already aforementioned documents Nos 2 to 77, according to the proper procedure, on the Tax Portal.
c) The vehicles referred to above were transferred to third parties on the dates contained in documents Nos 78 to 133, attached in annex with the arbitral request, which are considered fully reproduced.
d) The Tax Authority did not notify the Applicant of any official assessment of IUC relating to any of the vehicles contained in the present case file;
e) The Applicant did not present an Administrative Complaint in relation to the IUC assessments, the payment of which it effected, and which it challenged in the present case file.
B) FACTS NOT ESTABLISHED
There are no facts not established which are relevant for the decision to be rendered.
C) SUBSTANTIATION OF ESTABLISHED FACTS
The facts described above were considered established on the basis of the documents which the parties attached to the present case, the Applicant in annex to the request filed and the Tax Authority in the Administrative case sent to the case file.
IV – ISSUES TO BE DECIDED AND SUBSTANTIATION OF LAW
It is therefore necessary to assess and decide the issues to be resolved.
As a preliminary matter, the Tax Authority raised the issue of irregular certification of the power of attorney attached to the case file by the Applicant's representative. Such irregularity was, however, duly remedied.
Considering the positions assumed by the Parties in the arguments presented, the exceptions raised by the Tax Authority must first be assessed, relating to:
A) Lack of subject matter and
B) Omission of prior Administrative Complaint generating material incompetence of the Arbitral Tribunal
Thus, these issues are preliminary and precedent with respect to the other legal issues raised by the parties. The illegality of the IUC assessment acts and respective compensatory interest at issue in the present case file, as well as the right to restitution of the amount of tax paid and any eventual right to indemnity interest, shall only be assessed should these exceptions be judged unfounded.
Let us therefore analyze the first issue to be decided, namely, the examination of the exceptions raised by the Tax Authority.
A) Regarding Lack of Subject Matter:
The Respondent alleges that there are not, contrary to what the Applicant alleges, tax assessments in question, but merely collection notes, which do not constitute a tax act. Thus, we would be faced with a situation of lack of subject matter generating incompetence of the arbitral tribunal, given that the means of challenge against this type of acts should be the procedural route of filing a Special Administrative Action and not the filing of a request for arbitral determination here used by the Applicant. Further to this, the Tax Authority alleges that the Arbitral Tribunal is materially incompetent to assess and decide on the matter in dispute, given the non-existence of official IUC assessment acts issued by the Tax Authority. In the Respondent's view, such situation constitutes a dilatory exception preventing the examination of the merits of the case, given the provisions of articles 576, Nos 1 and 2 of the Code of Civil Procedure, by virtue of article 2, subparagraph e), of the Code of Administrative Tax Procedure and article 29, No. 1, subparagraphs a) and e) of the RJAT.
Well now, as to this issue, it is important to consider the nature of documents Nos 2 to 77 attached to the case file, and, having examined its content, to extract therefrom whether these show merely a collection note, as the Tax Authority intends, or something more than that. Now, having examined the said documents, there is no doubt whatsoever that we are not faced with mere "collection notes", as the Tax Authority intends.
In fact, it is very clear that the documents in question contain the typical elements of a tax assessment, with even the demonstration of interest due shown in the said document, which clearly induces the liable person to conclude that it is in arrears with the payment of the tax and it is its obligation to effect its payment, under pain of suffering all the harmful effects resulting from its non-compliance.
In the concrete case, the assessment of the tax, in a strictly technical-legal sense, was effected, or issued by the liable person itself, in accordance with the proper procedure provided for in the law for this purpose and in accordance with the rules implemented by the Tax Authority itself. And, thus, the Respondent's argumentation in this matter is not understood when it alleges that these are mere collection notes from which to conclude the absence of a challengeable tax act.
In truth, it is not official assessments as the Applicant invokes, but rather self-assessments, which are true tax acts.
It is important, in this regard, to bear in mind the provisions of article 16, No. 2 of the IUC Code, from which, indeed, results as a rule that "the assessment of the tax is made by the liable person itself via the internet, under the conditions of registration and access to electronic declarations, being mandatory for legal persons".
And article 4 of the same legal provision adds that "it is at the moment of that assessment of the tax that the single collection document is issued which, certified by the means in use in the collection network, proves the proper payment of the tax".
It is understood, therefore, that in light of the provisions of the law, despite the fact that the Tax Authority did not proceed with the issuance of an official tax assessment, under the terms and with the meaning provided for in article 18, No. 2 of the IUC Code, from this cannot be extracted the conclusion invoked by the latter, according to which we are faced with mere collection notes and not challengeable tax acts. The truth is that these were available in the private section of the liable person of the Tax Portal, with explicit indication of the amounts in arrears and with demonstration of assessment of compensatory interest. Any ordinary citizen would understand such "collection note", as the Tax Authority intends, with the same meaning that the now Applicant attributed to it, which merely complied with the legal procedure and issued the respective self-assessments and effected its payment.
The fact that the assessments were produced on the initiative of the liable person, as the Tax Authority further alleges, can only have the meaning that the law itself attributed to it, by providing the system contained in article 16 of the IUC Code. Now, it would be entirely unacceptable for the liable person to be penalized for complying with the legal procedures provided for. The thesis of the Tax Authority is therefore not followed, according to which, in the case sub judice, there are no tax assessments or that these are not true tax acts, hence the lack of subject matter and the material incompetence of the arbitral Tribunal. Thus also decided the Arbitral Tribunal in the decision rendered in case No. 183/2014, which, moreover, was invoked by the Respondent within the scope of the present case file.
As to the arguments adduced by the Respondent in the reply to this exception as regards the practice of any eventual criminal offense, this Tribunal understands it has no competence to rule thereon, being incumbent upon the Respondent to exercise the legally provided means of defense that it considers appropriate.
In conclusion, as to the first exception raised by the Tax Authority, it is the understanding of this Arbitral Tribunal that the self-assessments in question in the present case file are tax acts and, as such, can be challenged under the legally provided terms, one of the means being recourse to the request for arbitral determination, under the terms of article 2, No. 1, subparagraph a) of the RJAT, which provides for the possibility of examination of the legality of tax assessment and self-assessment acts. Thus, the Respondent Tax Authority is not right in the invoked dilatory exception of material incompetence of the Arbitral Tribunal due to lack of subject matter, which is considered unfounded.
B) Regarding Omission of Prior Administrative Complaint:
Turning now to the analysis of the second exception raised, the Tax Authority alleges that should it be understood that these are self-assessments generated by the Respondent itself on the Tax Portal, then it must be concluded, nevertheless, to the incompetence of the Arbitral Tribunal, due to omission of prior Administrative Complaint necessary.
Under the terms of the provisions of article 2, No. 1, subparagraph a) of the RJAT, the competence of arbitral tribunals includes the examination of the declaration of illegality of tax assessment acts, self-assessment, withholding at source and payment on account. Ordinance No. 112-A/2011 of 22 March, excludes from the competence of arbitral tribunals claims relating to the declaration of illegality of self-assessment acts which have not been preceded by recourse to the administrative route in accordance with articles 131 and 133 of the Code of Administrative Tax Procedure.
The issue which now arises is therefore as follows: the Tax Authority bound itself to the jurisdiction of arbitral tribunals, under the terms of Ordinance 112-A/2011, of 22 March, which have as their subject the examination of the legality of claims relating to taxes whose administration is entrusted to it, excluding claims relating to the declaration of illegality of self-assessment acts which have not been preceded by recourse to the administrative route, in accordance with the provisions of article 131 of the Code of Administrative Tax Procedure.
Now, in the case of the present case file, for all that has already been set forth above, this Tribunal understands that the acts in question whose declaration of illegality is being sought are characterized as self-assessments of IUC. As such, they should have been preceded by prior Administrative Complaint necessary, under the terms of article 131 of the Code of Administrative Tax Procedure, whereby, in this issue, the Tax Authority is right in the invoked exception of incompetence of this Arbitral Tribunal.
Having there been no prior recourse to the administrative gracious route in the case of the present case file, the Arbitral Tribunal lacks competence to judge this issue, as results from the provisions of article 2, subparagraph a) of Ordinance 112-A/2011, of 22 March. In this sense decided, in an identical situation, the Arbitral Tribunal constituted within the scope of Case No. 183/2014T, already mentioned above.
In these terms, it is concluded that the exception of absolute incompetence of this Arbitral Tribunal in respect of subject matter is well-founded. In consequence, the examination of the remaining legal issues raised by the parties is prejudiced.
V - DECISION
In light of the foregoing, this Arbitral Tribunal decides to judge well-founded the exception of absolute incompetence in respect of subject matter, under the terms and grounds set forth above, with the consequent dismissal of the instance of the Tax and Customs Authority.
Value of the Case: In accordance with the provisions of articles 306, Nos 1 and 2 of the Code of Civil Procedure, article 97-A, No. 1, subparagraph a), of the Code of Administrative Tax Procedure and article 3, No. 2 of the Rules on Costs in Tax Arbitration Cases, the value of the case is set at €6,392.24
Costs: In accordance with the provisions of article 22, No. 4, of the RJAT and in accordance with Table I annexed to the Rules on Costs in Tax Arbitration Cases, the amount of costs is set at €612.00, to be borne by the Applicant.
Let it be registered and notified.
Lisbon, 28 July 2014
The Singular Arbitrator,
(Maria do Rosário Anjos)
Text prepared by computer, under the terms of No. 5 of article 131 of the Code of Civil Procedure, applicable by remission of subparagraph e) of No. 1 of article 29 of Decree-Law No. 10/2011, of 20/01.
The writing of this decision is governed by the old spelling rules.
Frequently Asked Questions
Automatically Created