Summary
Full Decision
ARBITRAL DECISION
The arbitrators Fernanda Maçãs (arbitrator president), Dr. Isaque Marcos Lameiras and Dr. José Ramos Alexandre (members), appointed by the Deontological Council of the Centre for Administrative Arbitration to form the Arbitral Tribunal, hereby decide as follows:
REPORT
A... Lda. ("Claimant"), with tax identification number..., and with registered office at Av. ..., no. ... in Lisbon, submits a request for Arbitral Pronouncement to the effect that the illegality of the tax acts of assessment of Stamp Duty ("IS") carried out in 2015 be declared, pursuant to item 28.1 of the General Table of Stamp Duty ("TGIS"), amended by Law No. 55-A/2012, of 29 October and later repealed by Law No. 42/2016, of 28 December, in relation to urban properties of the type "land for construction", registered in the urban property register under articles ..., ..., ..., ..., ..., ... .
The request for constitution of the arbitral tribunal was accepted by the President of CAAD on 2018-04-27 and automatically notified to the Tax and Customs Authority.
The Claimant did not proceed with the appointment of an arbitrator, whereby, in accordance with the provisions of subparagraph a) of article 6, no. 2 and subparagraph b) of article 11, no. 1 of the RJAT, the President of the Deontological Council appointed the signatories as arbitrators of the collective arbitral tribunal, who communicated their acceptance of the appointment within the deadline.
On 16/04/2018 the parties were notified of the appointment of the arbitrators and raised no objection.
In accordance with the provisions of subparagraph c) of article 11 of the RJAT, the collective arbitral tribunal was constituted on 4 July 2018.
In these terms, the Arbitral Tribunal is regularly constituted to examine and decide the subject matter of the proceedings.
A - To support the request for arbitral pronouncement, the Claimant alleges, in summary, the following:
The claimant was notified to pay stamp duty as provided for in item 28.1 of the General Table of Stamp Duty, attached to the Code, assessed by AT with reference to the year 2015, in relation to 6 urban properties classified as land for construction, two registered in the property register of the parish of ...-Lisbon, another two registered in the property register of ...-Porto, plus one registered in the parish of ...-Lisbon and one last one registered in the property register of the Union of Parishes of ... and ..., municipality of Sintra, all properly identified in the records with the registration articles indicated above.
The Claimant considers that the norm of article 28.1 of the Table Annexed to the Stamp Duty Code is materially unconstitutional and, on the basis of this unconstitutionality, submits a request for declaration of illegality and consequent annulment of the assessments carried out pursuant to item 28.1 of the TGIS.
The Claimant bases its judgment of unconstitutionality of the said norm essentially on the case law of Constitutional Court Decision No. 250/2017, of 24 May, arguing that the said IS assessments violate the principle of equality enshrined in article 13 of the Constitution of the Portuguese Republic ("CRP"), and are, in parallel, contrary to the principle of fiscal equality and contributive capacity, enshrined in article 104, no. 3, of the same Statute, and are therefore unconstitutional.
The claimant further considers that the stamp duty assessments identified and demanded by AT do not correspond to its concrete activity (activity of buying and selling land for construction).
The Claimant argues that in commercial companies whose purpose consists of buying and selling real estate, the right of ownership over land for construction constitutes the patrimonial substrate of its economic activity, the essential means for pursuing its activity and not any manifestation of wealth, failing entirely the assumption that ownership of such land for construction could constitute evidence of superior contributive capacity.
The Claimant concludes that "It is clear from what has been said that the interpretation made by AT of item 28.1 of the TGIS materialises an unjustified negative discrimination of companies trading in land for construction, which implies its material unconstitutionality, by breach of the principles of equality and contributive capacity, whereby, once more, it must be concluded that the assessments are illegal due to errors in the factual and legal premises."
The Claimant also defends itself here with what is provided for this purpose in Constitutional Court Decision No. 250/2017.
On another plane of argumentation, the Claimant argues "that the IS assessments to which the land for construction held by it was subject did not attend to the building typology thereof, having been blind with respect to the specific purpose that will be given to them after construction is completed".
Considering the considerable number of housing units to be built on each plot of land for construction, these dwellings, when considered individually, will have a VPT well below the limit of €1,000,000.00.
The Claimant argues that "Thus, with IS provided for in item 28.1 applying to the VPT of land for construction determined as mentioned above, there will indisputably be unjustified discrimination when IS applies to land for construction before independent fractions/units capable of independent use are built, each with a value below €1,000,000.00."
"It is therefore to be concluded that the norm contained in item 28.1 is unconstitutional by breach of the principle of equality, as it applies to land for construction with VPT equal to or greater than €1,000,000.00, for which the authorized or planned construction does not include any independent fraction/unit capable of independent use with VPT greater than that reference point."
With reference to arbitral decision no. 507/2015-T of 17-03-2016, the Claimant states that there is an obligation "therefore, to adopt a restrictive interpretation of the provision, to the effect that plots of land for construction are subject to taxation, but, only and exclusively, in the case of construction authorized or planned for high-value dwellings, that is, for residential units of value greater than one million Euros." (emphasis ours)."
The Tax and Customs Authority responded and submitted the instructional file, presenting a defence by exception and by objection, in summary, with the following grounds:
The Arbitral Tribunal is materially incompetent to examine the request for declaration of material unconstitutionality of item no. 28 of the TGIS;
To obtain the grant of this alleged exception, AT considers that the claimant throughout its entire pleading does not attribute any illegality to the assessment acts, which are the subject of objection in the arbitral proceedings.
"It is manifest that the jurisdiction of the arbitral forum does not include the examination of the constitutional conformity of legislative acts or their norms, by virtue of article 2, no. 1 of the RJAT;
Whereby the Arbitral Tribunal is incompetent ratione materiae to examine the request for declaration of material unconstitutionality, «of item 28 of the General Table of Stamp Duty, by breach of the principle of contributive capacity, as a facet of the principle of equality, provided for in articles 13 and 104, no. 3 of the CRP.»).
Absolute incompetence ratione materiae constitutes a dilatory exception that prevents the continuation of the proceedings, leading to dismissal of the action as to the respective claim, in accordance with the provisions of articles 576, no. 2, 577, paragraph a) and 278, no. 1, paragraph a) of the CPC, applicable ex vi article 29, paragraph e) of the RJAT".
Defending itself also by objection, the Respondent considers that the assessments objected to result from the direct application of the legal norm, and which is expressed in objective elements, without any subjective or discretionary appreciation.
"Urban properties that are land for construction and to which residential allocation has been assigned within the scope of their respective valuations, such allocation being recorded in the respective registers, are subject to Stamp Duty.
Law No. 55-A/2012, of 29 October, which amended article 1 of the Stamp Duty Code, added item 28 to the General Table of this tax, whereby stamp duty now also applies to the ownership, usufruct or right of superficies of urban properties whose tax patrimonial value recorded in the respective register in accordance with the CIMI Code is equal to or greater than €1,000,000.00.
For tax purposes, the properties identified in the records are land for construction, as such were acquired and are thus classified for property purposes and, therefore, are undoubtedly plots of land for construction, more precisely urban properties with residential vocation.
Note that the legislator does not refer to 'property intended for housing', but has opted for the notion of 'residential allocation', an expression different and broader, whose meaning is to be found in the need to integrate other realities beyond those identified in article 6, no. 1, paragraph a) of the CIMI.
That is, the legislator merely defined, without room for doubt, the logical element underlying the statement of reasons that served as the basis for Legislative Proposal No. 96/XII.
Whereby the assessments now objected to remain entirely valid and lawful."
C - As there were no reasons to justify it, the tribunal dispensed with the holding of the first meeting provided for in article 18 of the RJAT, which it did in exercise of the principles of tribunal autonomy in case management. The Tribunal set 4 January 2012 as the date for the pronouncement of the decision.
D - The Claimant and the Respondent submitted allegations reiterating the arguments presented in the previous procedural documents.
DISMISSAL OF PRELIMINARY OBJECTIONS
The Respondent raises the exception of material incompetence because this Tribunal is, in its view, incompetent ratione materiae to examine the request for declaration of material unconstitutionality «of item 28 of the General Table of Stamp Duty» by breach of the principle of contributive capacity, as a facet of the principle of equality, provided for in articles 13 and 104 of the CRP».
First and foremost, it must be clarified that the Claimant merely bases the illegality of the assessment objected to on non-conformity of item 28 of the General Table of Stamp Duty by breach of Constitutional norms and does not properly request a declaration of unconstitutionality of that norm.
That being so, it is true that the Respondent is directly subject to the law and must act in conformity therewith. This fact does not, however, prejudice the right of individuals to raise, in disputes submitted for judgment before courts, the unconstitutionality of certain norms, nor can it prevent courts, including arbitral ones, from examining questions of unconstitutionality placed before them, by applying or disapplying the norms in question, in exercise of the powers constitutionally conferred (cfr. articles 204, 209 and 280 of the CRP).
With regard to an identical question, we follow the arbitral decision of 04-05-2018, delivered in Case No. 675/2017-T, of CAAD, in the part in which it states:
"There would certainly be some misunderstanding, for, in a State governed by the rule of law, it is to the Courts and not to any other bodies, in particular those with legislative and executive functions, that it falls to administer justice, «to ensure the defence of the rights and interests legally protected of citizens, to repress the breach of democratic legality and to settle conflicts of interests public and private» (articles 202, nos. 1 and 2, of the CRP), for which they must interpret and apply laws to settle disputes between citizens and the Administration.
It is also to the Courts that the CRP attributes the power to control the constitutionality of laws, issued by bodies with legislative power (article 204 of the CRP).
This decision is delivered by a Court, whereby it has a jurisdictional character, and in the exercise of its jurisdictional power it falls to it to apply the law, according to its interpretation, being subject only to the law, as it interprets it, not being obliged to adopt the interpretation adopted by the Tax and Customs Authority or that which would hypothetically be adopted by bodies with legislative power if they were attributed the competence to apply the law to disputes pending before the Courts.
On the other hand, in the exercise of its interpretative activity the Arbitral Tribunal is not limited by the letter of the law, and must adopt all criteria of interpretation provided for in the law, in particular those indicated in article 9 of the Civil Code and 11 of the LGT: «interpretation should not be limited to the letter of the law, but should reconstruct from the texts the legislative intent, taking especially into account the unity of the legal system, the circumstances in which the law was drawn up and the specific conditions of the time in which it is applied», only being unable to consider «the legislative intent that does not have in the letter of the law a minimum of verbal correspondence», which may even be «imperfectly expressed»".
In sum, it is not asked of the Respondent to proceed with the application or disapplication of norms due to unconstitutionality. This request is directed to the courts in general, including arbitral ones, in cases submitted for judgment.
Therefore, the alleged exception fails.
The Parties have legal personality and capacity, show themselves to be legitimate and are properly represented (articles 4 and 10, no. 2, of the RJAT and article 1 of Ordinance No. 112-A/2011, of 22 March).
The cumulation of claims offers no obstacle, as there is identity of the tax, as well as of the factual and legal grounds invoked.
The proceedings do not suffer from any defects.
The Arbitral Tribunal is regularly constituted and is materially competent to know and decide the claim [cfr. article 2, no. 1, paragraph a) of the RJAT].
No other circumstances exist that prevent the examination of the merits of the case.
MERITS
III.1. Facts
Established Facts
With relevance to the examination and decision of the questions raised, preliminary and substantive, the following facts are taken as established and proven:
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The Claimant, in the year 2015, was the owner of the urban properties described as follows:
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Property registered in the urban property register in the parish of ..., district and municipality of Lisbon, under registration article...;
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Property registered in the urban property register in the parish of ..., district and municipality of Lisbon, under registration article ...;
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Property registered in the urban property register in the parish of ..., district and municipality of Porto, under registration article ...;
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Property registered in the urban property register in the parish of ..., district and municipality of Porto, under registration article...;
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Property registered in the urban property register in the parish of ..., district and municipality of Lisbon, under registration article ...;
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Property registered in the urban property register in the parish of Union of Parishes of ... and ..., municipality of Sintra, district of Lisbon, under registration article ...;
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As appears from the respective property records, the said urban properties are all properties classified as land for construction and have a Tax Patrimonial Value ("VPT") exceeding €1,000,000.
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In relation to the year 2015, AT issued IS assessments provided for in item 28.1 of the TGIS, applying the rate of 1% to the patrimonial value of the said urban properties of the type "land for construction", on 5 April 2016, determining the following collection amounts:
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Urban property with registration article ... - assessment of €21,075.00;
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Urban property with registration article ...- assessment of €32,323.00
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Urban property with registration article ... - assessment of €22,984.90
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Urban property with registration article ... - assessment of €19,937.10;
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Urban property with registration article ... - assessment of €34,141.80;
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Urban property with registration article ... - assessment of €55,521.27;
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The Claimant proceeded to pay the collection notes relating to the first instalment on 26 April 2016, to pay the collection notes relating to the second instalment on 25 July 2016 and to pay the collection notes relating to the third instalment on 23 November 2016, as evidenced by documentation attached to the file.
The Tribunal considers that no other fact relevant or essential to the examination of the claim was proved or not proved.
Grounds regarding proof
It is known that the judge (or the arbitrator) does not have the duty to pronounce on all the alleged matters, but rather has the duty to select only that which is relevant to the decision, considering the cause of action which grounds the claim formulated by the claimant and to decide whether he considers it proved or not proved.
On the other hand, according to the principle of free evaluation of evidence, the Tribunal should base its decision, in relation to the evidence produced, on its intimate conviction, formed from the examination and evaluation it makes of the means of evidence brought to the proceedings and in accordance with its experience of life and knowledge of people and surroundings.
In this case, the Tribunal formed its conviction on the basis of critical analysis of the documents presented by the party, which were not contested, and on a copy of the instructional administrative file, presented by AT, having also taken into account that none of the alleged factual matter was contested or objected to.
III.2. Legal Issues
III.2.1. On the illegality of the assessment
Examining the records, it appears that the Claimant bases the illegality of the tax acts sub judice essentially on their non-conformity with the Constitution of the Republic (material unconstitutionality) of the tax incidence norm contained in item no. 28.1 of the General Table of Stamp Duty ("hereinafter abbreviated as TGIS"), attached to the Stamp Duty Code, in the version given by Law No. 83-C/2013, of 31 December.
Under this norm, Stamp Duty is levied on:
"28 – Ownership, usufruct or right of superficies of urban properties whose tax patrimonial value recorded in the register, in accordance with the Property Tax Code (CIMI), is equal to or greater than (euro) 1,000,000 – on the tax patrimonial value used for IMI purposes:
28.1 – Per residential property or per land for construction whose construction, authorized or planned, is for housing, in accordance with the provisions of the Property Tax Code – 1%".
The Claimant considers that the said norm is unconstitutional by breach of the principles of equality and contributive capacity, basing its argumentation extensively (e.g. §.45, 58, 62, 73 and 84 of the Request for Arbitral Pronouncement) on the case law contained in Constitutional Court Decision No. 250/2017, dated 24 May 2017 and delivered in the course of Case No. 156/2016 (Rapporteur Cláudio Monteiro).
To support the decision of unconstitutionality, and synthetically, it was argued in this judgment that, since item 28.1 of the TGIS purports "to constitute a supplementary IMI rate, aimed at discriminating properties of higher tax patrimonial value and subjecting them to a heavier tax regime than the remaining ones (…) it should encompass, or at least consider, the whole of each taxpayer's real estate patrimony, under penalty of affecting different taxpayers in an excessively unequal manner. All the more so because the tax in question is not progressive, and because it is therefore enough that the tax patrimonial value of a property be lower by only one euro from the million required by the said item for its owner to have nothing to pay, even if he is the owner of several properties of that value". And it continues: "That, by not expanding the tax base, at least, to the whole of each taxpayer's real estate patrimony, not personalizing the tax sufficiently, that item did not prove to be adequate to pursue "the principle of social equity in austerity, guaranteeing an effective sharing of the sacrifices necessary to fulfil the adjustment programme, as the legislator intended in the statement of reasons of Legislative Proposal No. 96/XII/2nd, which was the origin of the said Law No. 55-A/2012."
Additionally, the Court states that "by bringing together in the same item the taxation of luxury homes and land for construction, on the assumption that both are generically subsumed under the category of real estate assets of high tax patrimonial value, the norm whose validity is being discussed confused manifestations of wealth with factors of production of that same wealth."
In fact, it continues, "behind the tax imposed on the owner of a residential property of tax patrimonial value exceeding one million euros there may be a taxpayer with sufficient economic strength to bear the respective tax burden, behind the tax imposed on the owner of a plot of land for construction there will normally be an entrepreneur, usually in the form of a commercial company dedicated to real estate development, about whose economic strength we know nothing. In truth, we cannot presume that such taxpayer has economic strength proportional to the value of the land, which is merely instrumental in relation to its economic activity. We do not know what profit margin he will draw from its exercise, if he is in the legal and economic conditions to develop it, or whether he may not even have a negative balance sheet position."
Thus, in summary, and appealing to the principle of contributive capacity as a criterion of fiscal equality, the Constitutional Court concluded on the unconstitutionality of item no. 28.1 of the General Table of Stamp Duty.
It should be noted that the matter of the alleged unconstitutionality of item 28.1 of the TGIS and, in particular, following the amendments introduced by article 194 of Law No. 83-C/2013, of 31 December, was the subject of various Arbitral Decisions in different directions.
For example, and arguing for the unconstitutionality of the norm in the same sense that the Constitutional Court would later do in Decision No. 250/2017 of 24 May, see the Arbitral Decision dated 17 March 2017 delivered in the course of Case No. 507/2015-T (Jorge Lopes de Sousa) and, already at a later moment, the Arbitral Decisions dated 02/10/2017 and 27/06/2018 and delivered, respectively, in the course of Cases Nos. 152/2017-T (Sérgio Santos Pereira) and 603/2017-T (Marcolino Pedreiro).
In a different sense, for example, see the decisions dated 15/12/2015, 20/01/2016, and 28/04/2016 and delivered, respectively, in the course of Cases Nos. 515/2015 (Magda Feliciano), 517/2015 (Mariana Vargas) 516/2015 and (Baeta de Queiroz)[1].
It happens, however, that the matter was recently re-examined by the Plenary of the Constitutional Court which, in Decision No. 378/2018, dated 4 July 2018 and delivered in the course of Case No. 156/2016 (Rapporteur João Caupers)[2], concluded on the non-unconstitutionality of the norm expressly revoking Decision No. 250/2017 of 24 May.
In said judgment, and synthetically, the (Plenary of the) Constitutional Court attributes to the decision of unconstitutionality contained in the aforementioned Decision No. 250/2017 a "methodological flaw" and which consists in considering that "there is constitutionally censurable inequality because the owner of a single residential property of tax patrimonial value equal to or greater than €1,000,000 is taxed and the owner of several properties with such allocation whose individual tax patrimonial value is less by only one euro from the amount set in that item is exempt from tax."
In fact, the Court considers that: "analyzing the problem of unconstitutionality from the perspective of the legal situation selected as determining the application of the tax – that of ownership of a single plot of land for construction of value equal to or greater than €1,000,000.00 whose construction, authorized or planned, is for housing –, the judgment of unconstitutionality, by breach of the principle of fiscal equality, which the appealed decision directs to item 28.1 of the TGIS does not appear to be justified."
Now, it continues, "the tax provided for in Item 28.1, as is proper of taxes on patrimony, delimits its scope of application by reference exclusively to the ownership of certain patrimonial values, «regardless of the function performed by such assets (productive capital, application of funds or savings or durable consumption)» (Summary Decision No. 214/2017). On the other hand, being a tax on patrimony, it also does not individualize or distinguish the respective passive subjects by recourse to any criterion other than precisely the ownership of those patrimonial values. Thus, it applies indiscriminately to natural persons and legal entities and, within this category, to associations, foundations and commercial companies, regardless of the economic sector in which the latter operate and the specific commercial risks existing in the respective sectors of activity, moreover proper to any and all commercial activity."
Thus, the Constitutional Court states, "the choice for such a model of taxation is constitutionally legitimate, being virtually apt, with such configuration, to pursue the programme that the Constitution associates with it of contributing to equality among citizens, nor does it follow from the argumentation expended in the decision under appeal any grounded demonstration that there effectively occurs «intolerable arbitrariness» in the normative choice to extend the incidence of said tax to land for construction.
In fact, it continues, "if it is true that the mere ownership of plots of land for construction for dwellings of value equal to or greater than €1,000,000.00 does not, in itself alone, allow determining the specific and complete economic-financial situation in which the passive subject of the tax finds himself – which, it is repeated, is not constitutionally required –, it also does not authorize extrapolative judgments about the type of taxpayers affected by such incidence norm, the economic sector in which they operate and the conjunctural vicissitudes, particularly of the market, to which they may be subject."
Moreover, for the Constitutional Court, "the mere statistical probability of being affected by the norm in question of commercial companies dedicated to real estate development, associated with the consideration of economic variables of uncertain verification, such as the economic impact of the tax in that particular branch of commercial activity – whose value, moreover, will not fail to be considered as a cost of activity –, does not constitute a sufficiently solid reason to support a judgment of unconstitutionality of the norm in question, in the specific case under examination, considering, moreover, the negative character of constitutional control dictated by the principle of equality."
Finally, and with regard to the argument that the taxation of land for construction is based on the future possibility of residential construction thereon without considering the respective building typology and legal structure, the Constitutional Court states: "(…) what is relevant for the purposes of application of the norm of item 28.1 is the legal-patrimonial situation existing on the date of maturity of the tax payment obligation, being thus by reference to the specific tax fact existing on that date that the existence or non-existence of a rational or reasonable ground to justify the legal-tax consequences immediately arising therefrom should be evaluated.
The legally relevant transformations that the object of property may undergo in the course of time, from that moment onwards, resulting in particular from the possibility of a building consisting of independent fractions of lower value being constructed on a plot of land for construction of tax patrimonial value exceeding €1,000,000.00, constitute hypotheses of verification and uncertain content, even taking into account the existence of licensing on those terms, which may be altered or not even used. They cannot therefore have a decisive bearing on the evaluation of the constitutionality of norms, or segments thereof, which, by virtue of their occurrence, will cease to be applicable.
The only certain fact that, within the applicable legal framework, can and should be examined, at the constitutional level, is the ownership, at the moment of maturity of the tax obligation in question, of real property rights of enjoyment over a plot of land for construction of tax patrimonial value equal to or greater than €1,000,000.00, whose construction, authorized or planned, is intended for housing."
On the basis of the argumentation briefly transcribed above, the Constitutional Court decided:
"a) Not to find unconstitutional the norm contained in Item 28.1 of the General Table of Stamp Duty, approved by Law No. 55-A/2012, of 29 October, and amended by Law No. 83-C/2013, of 31 December, insofar as it imposes annual taxation on the ownership of land for construction whose construction, authorized or planned, is for housing, whose tax patrimonial value is equal to or greater than (euro)1,000,000.00;
b) Grant the appeal filed by the Tax and Customs Authority;
c) Revoke Decision No. 250/2017."
The content of said judgment, to which this Arbitral Decision cannot fail to anchor itself, fully covers all the questions of unconstitutionality raised by the Claimant.
The Claimant's thesis also fails insofar as a restrictive interpretation of item 28.1 of the TGIS is said to be the most conformable with the Constitution. The wording of the provisions in question is sufficiently clear and unambiguous in the sense of the case law contained in the aforementioned Tribunal Decision, with no space for the interpreter to have to choose between two possible interpretations of that norm most friendly to the Constitution.
For all the above, it is concluded that the present Request for Arbitral Pronouncement is unfounded, with the consequent maintenance in the legal order of the IS assessments now objected to.
III.2.2. On Compensatory Interest
Given that the illegality pointed out by the Claimant to the tax acts in question is not verified, the request for compensatory interest formulated by it is rendered moot.
DECISION
In these terms and with the grounds set out above, the tribunal decides,
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To dismiss the exception raised;
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To find the Request for Arbitral Pronouncement wholly unfounded, with the consequent maintenance in the legal order of the IS assessments objected to;
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To condemn the Claimant to pay the costs of the present proceedings.
V. Value of the case
In accordance with the provisions of article 305, no. 2, of the CPC and 97-A, no. 1, paragraph a), of the CPPT and article 3, no. 2, of the Regulation of Costs in Arbitration Proceedings in Tax Matters, the value of the case is fixed at €185,983.07 Euros.
VI. Costs
Pursuant to article 22, no. 4, of the RJAT, and Table I attached to the Regulation of Costs in Arbitration Proceedings in Tax Matters, the amount of costs is fixed at €3,672.00, to be borne by the Claimant.
Let it be notified.
Lisbon, 13 December 2018.
The arbitrators,
Fernanda Maçãs (president)
Dr. Isaque Marcos Lameiras (member)
Dr. José Ramos Alexandre (member)
[1] All available at https://caad.org.pt/tributario/decisoes/.
[2] Available at http://www.tribunalconstitucional.pt.
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