IMT Tax Exemption Under Article 270 CIRE: Insolvency Property Transfer Ruling (CAAD 367/2016-T)

ARBITRAL DECISION

I – REPORT

A) The Parties and the Constitution of the Arbitral Tribunal

1. A… lda, legal entity no.…, with registered office at Rua…, nº…, …-… Lisbon, hereinafter referred to as "Claimant", filed a request for the constitution of an Arbitral Tribunal, pursuant to the provisions of paragraph a) of no. 1 of article 2º, no.1, paragraph a), article 3º, no.1, article 6º, no.1 and article 10.º, no. 1, paragraph a), of Decree-Law no. 10/2011, of 20 January, hereinafter referred to as "RJAT", for the challenge of the dismissal order of the Gracious Complaint, which was processed under no. … 2016…, concerning the levy of Municipal Tax on Paid Transfers of Real Estate (IMT), with the no.…, in which the Tax and Customs Authority is the Respondent, hereinafter referred to as "AT". The Claimant seeks the declaration of illegality of the dismissal order of the gracious complaint and the underlying act of levy of IMT and its annulment with the legal consequences.

2. The request for constitution of the arbitral tribunal was presented on 05-07-2016, was accepted by the President of CAAD on 07-07-2016 and, immediately, the Tax and Customs Authority was notified of its presentation. Under the provisions of paragraph a) of no. 2 of article 6.º and paragraph b) of no. 1 of article 11.º of the RJAT, as amended by article 228º of Law no. 66-B/2012, of 31 December, the Deontological Council appointed the undersigned, on 06-09-2016, as arbitrator to compose the sole arbitral tribunal. Immediately, the parties were duly notified of this appointment, and they did not manifest the intention to refuse the appointment of the indicated arbitrators, in accordance with the combined provisions of article 11.º no. 1 paragraphs a) and b) of the RJAT and articles 6.º and 7.º of the Deontological Code. Thus, in conformity with the provisions of paragraph c) of no. 1 of article 11.º of the RJAT, as amended by article 228º of Law no. 66-B/2012, of 31 December, the sole arbitral tribunal was constituted on 21-09-2016. On 26-09-2016 an arbitral order was issued, pursuant to the provisions of article 17º of the RJAT, and the AT was notified to present its defence within the statutory period.

3. The Tax and Customs Authority replied on 28-10-2016, and attached to the file the respective administrative process (PA). In its response, which is deemed to be fully reproduced herein, the AT contends for the legality of the challenged acts and for the dismissal of the claim. It requests that the meeting provided for in article 18º of the RJAT be dispensed with, as unnecessary, as well as the presentation of arguments, given that the documentary evidence attached to the file is sufficient to render the decision, which concerns, exclusively, matters of law.

4. No exceptions were invoked nor witness evidence requested, the questions to be decided by the tribunal being exclusively matters of law. Thus, on 16-11-2016, an arbitral order was issued with the following content:

"Having examined the Petition for arbitral pronouncement submitted by the Claimant and the Reply attached to the file by the AT, it is found that there is no witness evidence to be produced and that the questions to be decided are exclusively matters of law to be decided by this Tribunal.

In the reply presented, the Respondent AT expressly manifested its agreement to any dispensation of the meeting referred to in article 18º of the RJAT, as well as to the presentation of arguments. Accordingly, said meeting appears dispensable, as well as the presentation of arguments. Nevertheless, the parties may present written arguments, if they wish, within 10 days (equal and successive), after which the process shall proceed to final decision, to be rendered by 23 December 2016.

The parties are invited to send to the file their respective procedural documents in Word format.

The Claimant is notified to effect the payment of the subsequent arbitration fee within 10 days before the date set for final decision."

1. The Claimant and Respondent stated their positions, respectively, on 17-11-2016 and 28-11-2016, informing that they did not wish to present arguments. The Claimant effected payment of the subsequent arbitration fee.

B) PROCEDURAL PREREQUISITES:

1. The arbitral tribunal was regularly constituted. The parties have legal personality and capacity, are legitimate and are represented (articles 4.º and 10.º, no. 2, of the same statute and article 1.º of Ordinance no. 112-A/2011, of 22 March). The process does not suffer from nullities that prevent the examination of the merits of the case.

It is necessary to examine and decide on the merits of the claim.

II. FACTUAL MATTERS

A) Proven Facts

1. Based on the elements contained in the process, attached to the file, the following relevant facts are considered proven for the examination of the merits of the case:

a) The Claimant is a commercial company whose corporate purpose is the acquisition and sale of real property.

b) In the exercise of its activity the Claimant assumed the position of creditor of the commercial company B…, Lda, with the TIN…;

c) The Claimant acquired the real property situated in the Parish of … (extinct), with the registration number …; registered in the name of the company B…, Lda;

d) The acquisition of this real property took place within the framework of the insolvency process of the said company B…, Lda, with the Claimant acting in the capacity of creditor of this company;

e) By virtue of this acquisition, the exemption from IMT provided for in article 270.º of the Code on Insolvency and Corporate Recovery ("CIRE") was automatically recognized to the Claimant, not having thus levied tax with reference to that transaction;

f) The Claimant was notified on 6-10-2016, of the official communication attached to the file as an appendix to the arbitral petition as document no. 3, which determines the payment of IMT concerning the acquisition of the real property in question, with the notice that the respective levy will be processed;

g) This notification clarifies that, in the understanding of the services, there was an incorrect application of the exemption in IMT within that transaction, since, in the acquisition of the real property in question, the necessary conditions for the application of no. 2 of article 270.º of the CIRE would not have been met, since it did not acquire the "universality of real property of the insolvent company";

h) The AT proceeded to issue the levy of IMT in the total amount of €33.844,75 and surcharges in the amount of €695,29, totalling €34.540,04, as shown in document no. 2 appended to the arbitral petition, which is deemed to be fully reproduced herein;

i) The Claimant effected payment of the levied amount of IMT and surcharges, within the scope of the tax enforcement process meanwhile instituted;

j) On 18-02-2016, the Claimant deduced a gracious complaint based on the illegality of the levy act;

k) On 15-04-2016, the Claimant was notified of the definitive order dismissing the gracious complaint deduced;

l) On 05-07-2016 the Claimant presented this request for constitution of an arbitral tribunal.

B) Unproven Facts

1. There are no facts with relevance for the examination of the merits of the case that are considered unproven.

C) Justification of the Determination of Factual Matters

1. The proven facts are based on documents attached to the file by the Claimant and attached to the file, admitted by the Respondent, so there are no disputed facts. There is no divergence between the parties regarding the facts mentioned in the file, but rather, exclusively, regarding the legal question underlying the challenged levy. It should be noted that the factual matter on which the Tribunal has the duty to pronounce is not all that was alleged and proven, but only and exclusively that considered relevant or with interest or relevance to the decision (See articles 591º, 592º, 596º and 607º of the CPC and 123º-2 of the CPPT, applicable by virtue of article 29º of the RJAT).

III - LEGAL MATTERS

1. It results from the file, as verified by the summary of the factual matters set out, that the question to be decided is whether the purchase of one or several real properties, within the framework of a liquidation process of the insolvent company is (or is not) exempt from IMT, in accordance with the provisions of article 270.º, no. 2 of the CIRE. The Claimant deduces this arbitral petition in defence of its right to the exemption from IMT in the acquisition of the real property above identified, understanding that this benefit results from the provisions of no. 2, article 270º of the CIRE. It understands that this normative provision exempts from IMT, not only in the acquisition of the universality of property of the insolvent (in which one or more real properties are included), but also in the paid transfers of real properties, by sale, barter or assignment of the company or of establishments thereof integrated within the framework of insolvency plans, payment plans or recovery plans or carried out within the framework of the liquidation of the insolvent estate.

2. The transmission in question is, without doubt, a transmission effected through sale, carried out within the framework of the liquidation of the insolvent estate. Which, from the perspective of the Claimant, benefits from exemption from IMT, so the challenged levy is illegal.

However, the interpretation that the Claimant and Respondent make of this legal normative provision is different. From the perspective of the Claimant, the AT in interpreting this legal provision in the sense that the exemption from IMT applies only in the case of acquisition of the universality of property of the insolvent estate, violates the letter and spirit of the law, illegally restricting the right to exemption established therein.

1. The AT alleges in defence of its position, in summary, various interpretive arguments, extracted from the letter of article 270º of the CIRE, rebutting the Claimant's argument regarding the Government's binding to article 9º of the legislative authorization law (Law no.39/2003), cites part of the jurisprudence in the Judgment of the Supreme Administrative Court of 03/07/2013, although this Judgment refers to the interpretation of the previous wording of no.2 of article 270º of the CIRE, and, finally, invokes that the AT is bound either by the principle of legality, or by internal guidelines issued by the AT. To this effect it invokes the content of the binding information issued in process 2009… – IVE no.…, with the agreeing order of the Sub-Director-General of Taxes for the Asset Area, according to which:

"The application of the fiscal benefits of article 270.º no. 2 of the C.I.R.E. depends on the real properties transferred being integrated into the universality of the company or establishment sold, bartered or assigned within the framework of the insolvency plan or payment plan or the liquidation of the insolvent company."

In this way, the Respondent concludes that the acquisition did not have as its purpose the continuation of the same activity, nor did the acquisition involve the purchase of the universality of all property affected to the activity of the insolvent company and that the sale of property of the company, in isolation, is not covered by the exemption provided for in no. 2 of article 270.º of the CIRE, being therefore, subject to IMT under the general terms.

It is necessary to decide.

1. To this effect, our superior courts have already pronounced themselves, on various occasions. Also within the scope of CAAD, in numerous processes, sole and collective arbitral tribunals have already pronounced themselves on the question under debate. To this effect, we shall follow closely the arbitral jurisprudence contained in the Arbitral Decisions 95/2015-T, 99/2015-T, of 27 October, as well as in the Arbitral Judgment rendered in process 599/2015-T, of 10-02-2016, on the interpretation of article 270º, no.2 of the CIRE, with developed explanation on the scope and extent of the IMT exemption established therein, to which we adhere. This arbitral jurisprudence appears, moreover, to be in line with the jurisprudence of the Supreme Administrative Court (STA), contained in various judgments. It stands out, first of all, the Judgment no. 0949/11, of 30 May 2012, due to its similarity with what is cited by the AT in its Reply, in which the following understanding is reproduced:

"In light of the letter of the law, either of the two interpretations is defensible, appearing, however, grammatically more correct the one sustained by the tax administration, since the verbs 'sell', 'barter' and 'assign' are all transitive verbs, so that in the sentence the reference to 'the company or establishments thereof' appeared as the direct object of all three. However, this interpretation conflicts – as well observed in the appealed sentence – with what the legislator established in no. 49 of the preamble of the CIRE regarding fiscal benefits, where it states that: 'the regimes existing in the CPEREF are essentially maintained as regards the exemption of fees and fiscal benefits', being certain that paragraph c) of no. 2 of article 121.º of the CPEREF exempted from municipal surtax on transfers the transfers of real property integrated in any of the measures for corporate recovery that result, namely, from the sale, barter or assignment of elements of the company's assets. And it conflicts, also – as well observed by the Public Prosecutor's Office in first instance (see the opinion of pp. 66 to 68 of the file) – with the meaning and scope of the legislative authorization granted to the Government under which the CIRE was approved, fixed in articles 2.º and following of Law no.39/2003, of 22 August, since, as regards the exemptions from municipal surtax on transfers (today IMT), the provision of no. 3 of article 9.º of that legislative authorization law provided that: 'Finally, the Government is authorized to exempt from municipal surtax on transfers the following transfers of real property, integrated in any insolvency plan or payment plan or carried out within the framework of the liquidation of the insolvent estate: c) (…) from the sale, barter or assignment of the company, establishment or elements of its assets (…)'."

1. In the case being examined in this file, it is a matter of examining the legality of the levy, produced by the non-recognition/application to the Claimant of the exemption provided for in article 270.º of the Code on Insolvency and Corporate Recovery regarding the acquisition of the real property effected within the framework of the insolvency of the commercial company B… Lda, of which the Claimant was a creditor.

Now, this article 270.º of this Code on Insolvency and Corporate Recovery establishes the following:

Article 270.º

Benefit relating to the municipal tax on paid transfers of real property

1 - The following transfers of real property are exempt from the municipal tax on paid transfers of real property, integrated in any insolvency plan, payment plan or recovery plan:

a) Those intended for the constitution of a new company or companies and for the realization of its capital;

b) Those intended for the realization of the increase of the share capital of the debtor company;

c) Those resulting from payment in fulfillment of company property and from the assignment of property to creditors.

2 - The following are equally exempt from the municipal tax on paid transfers of real property: acts of sale, barter or assignment of the company or of establishments thereof integrated within the framework of insolvency plans, payment plans or recovery plans or carried out within the framework of the liquidation of the insolvent estate.

1. As results from the factual matters established that the Claimant acquired the real property within the framework of the liquidation of the insolvent estate of the company B… Lda, the situation is framed in no. 2 of this article. The interpretive doubts, evidenced in the positions of the parties in this process, arise from some lack of clarity in this no.2, which leaves open the question of whether the reference to sale relates only to the sale of the company (?) or of establishments integrated therein or whether it covers any real properties of the insolvent estate, even if transacted in isolation.

As mentioned previously, the Supreme Administrative Court has already pronounced itself on this question on various occasions, in the aforementioned Judgment, as well as in many others rendered over the past years, standing out the recent Judgment of the STA of 16-03-2016, rendered in process no. 788/14, with as rapporteur His Excellency Justice Counselor Pedro Delgado, in which it was decided that:

"The exemption from IMT provided for in no. 2 of article 270.º of the CIRE applies, not only to sales or barters of companies or establishments as universality of property, but also to sales and barters of real properties (as elements of its assets), provided that they are framed within the scope of an insolvency plan or payment plan, or carried out within the framework of the liquidation of the insolvent estate."[1]

1. It is verified that the direction of the decision, whether within the scope of arbitral jurisprudence or the jurisprudence of the STA, has been to consider that there are exempt from IMT not only the sales of the company or establishments thereof, as universalities of property, but also the sales of elements of its assets, provided that they are integrated within the framework of insolvency plan or payment plans or carried out within the framework of the liquidation of the insolvent estate.

Recall to this effect part of the reasoning contained in the Judgment of 17-12-2014, rendered within the scope of process no. 01085/13:

"(…) the property that makes up the insolvent estate consists of the property of the patrimony of the company declared insolvent and none other belonging to another natural or legal person. By definition, the property that is sold in an insolvency process is property of the insolvent or that, at least, was regarded as such. There is no sale of property other than those that made up the patrimony of the insolvent. The legislator, to guarantee that this is so, even provides for a procedure of claim for the restitution and separation of property intended to separate from the estate property of third parties improperly seized, or those of which the insolvent is not full and exclusive owner, or are foreign to the estate or unsuitable for seizure for the estate – article 141º of the Code on Insolvency and Corporate Recovery.

Furthermore, in the chapter on liquidation of the Code on Insolvency and Corporate Recovery, there are found clear and precise indications of the property that may be sold in that liquidation and those that should be temporarily or definitively excluded from the sale, with only the right that the insolvent has over property of which he/she is co-holder being liquidated in the insolvency process – article 159º – and not proceeding to the sale of property of controversial titularity until the judgment becomes final that defines the titularity of the right of ownership with respect to such property – article 160º.

The insolvency process is – article 1º of the Code on Insolvency and Corporate Recovery – a universal execution process whose purpose is the satisfaction of creditors in the manner provided for in an insolvency plan intended to promote the recovery of the company comprised in the insolvent estate, or, when such is not possible, to liquidate the patrimony of the insolvent debtor with the subsequent distribution of the product obtained among creditors. The insolvent estate encompasses all the patrimony of the debtor (…) so that it cannot be conceived that there are property constituting the insolvent estate of a company declared insolvent that could be integrated into a category of property without any relation to that company or establishment."

1. We fully adhere to this understanding. In fact, it further follows that, as well stated by all the arbitral jurisprudence and of the STA examined, that, if any doubt persists, the preamble of the CIRE itself, in point 49, states that the "regimes existing in the CPEREF are essentially maintained as regards the exemption of fees and fiscal benefits." As well stated in the Judgment of the STA of 30-05-2012 (process no. 949/11), "the meaning and scope of the legislative authorization granted to the Government under which the CIRE was approved (articles 2.º and following of Law no. 39/2003, of 22-08) as regards the exemptions from municipal surtax on transfers (today IMT), the provision of no. 3 of article 9.º of that legislative authorization law provided that: 'Finally, the Government is authorized to exempt from municipal surtax on transfers the following transfers of real property, integrated in any insolvency plan or payment plan or carried out within the framework of the liquidation of the insolvent estate: c) (…) from the sale, barter or assignment of the company, establishment or elements of its assets (…)'."

2. Now, in this framework, admitting that, in the implementation of the legislative authorization for the approval of the CIRE, the government decided to exclude this exemption in cases of sale, barter or assignment of elements of its assets, granting it only in cases of sale, barter or assignment of the company or its establishment, implies recognizing that, in that case, we would be before a violation of the legislative authorization law, that is to say, before disregard for the meaning and scope of the legislative authorization that was granted to it. This would necessarily imply recognizing that the government had legislated in a matter reserved for the Assembly of the Republic (see no. 2 of article 103.º and paragraph i) of no. 1 of article 165.º of the Constitution).

3. In any event, the resolution of the question is possible at the sub-constitutional level. From the text of the law (article 270º, nos. 1 and 2 of the CIRE) it is possible to extract, without difficulty, a meaning compatible with the obligation resulting from the legislative authorization law. It is, moreover, the duty of the interpreter of law, in case of doubt, to find the interpretation compatible with the text and constitutional obligations. We should not lose sight of the purpose that the legislator intends to achieve with the grant of such exemption, which consists in promoting and encouraging the quick sale of property comprising the insolvent estate, for the quicker and more effective satisfaction of the interest of creditors, the market and the general public interest, not forgetting the satisfaction of the credit of the State itself (tax credits and social security, predominantly). These are the reasons that led the legislator to grant the fiscal benefit of exemption from payment of IMT in the acquisition of these property or of the universality of property or establishments of the insolvent.

4. Thus, the interpretation of the legal text contained in no. 2 of article 270º of the CIRE can be interpreted, clearly and without difficulty, taking into account its "ratio legis". The question is whether the grant of the exemption from IMT is or is not an incentive for the acquisition of property of entities in the insolvency process, so as to prevent the dragging of the process and the non-satisfaction of credits against the insolvent. As well set out in the Arbitral Judgment no. 599/2015, of 10-02-2016, of CAAD, what is important is that we ask ourselves whether "to achieve the purpose previously defined makes any difference whether the company is being sold globally with all its assets and liabilities, whether one or more of the commercial establishments that comprised it are being sold, whether property that comprised its patrimony but was not used in its commercial activities are being sold – for example a real property received in payment of a debt of which the insolvent company was a creditor – so as to be before a sale that is carried out within the framework of the liquidation of the insolvent estate? And, if in the same situations it is not sales but barters or assignments – being that this word should have been used in an improper sense in that associated with the business world it usually refers to the assignment of operation, assignment of the commercial establishment, close to leasing and not alienation, and in the Code on Insolvency and Corporate Recovery it is shown to be used also as to the acquisition of property by creditors? We believe that the answer cannot but be negative.

No. 1 of article 270º of the Code on Insolvency and Corporate Recovery grants the exemption from IMT to the transfers of real property effected in fulfillment of:

1. insolvency plan

2. payment plan

3. recovery plan

provided that such transfers have as their purpose one of the following situations:

a. constitution of a new company or companies

b. realization of the capital of a new company or company

c. realization of the increase of the share capital of the debtor company

or result from:

i. payment in fulfillment of company property

ii. assignment of property to creditors.

No. 2 of this article, does not repeat the exemption that it established in no. 1, it extends it to persons who, external to the insolvency process, because they are not the creditors who acquired the property, the insolvent company that saw its share capital increased, or the company that was formed from this process, these, already contemplated in no. 1 of article 270º, but to those who acquire real property considered individually or integrated in the global or partial acquisition of the company."

1. It is concluded, then, that this interpretation is not only permitted by the letter of the law but also by its "ratio legis", being manifestly the only interpretation compatible with the objective of encouraging acquisitions of property of the insolvent company, allowing all interested parties a less burdensome outcome of the process.

2. Returning to the case of the present file, in line with the factual matters considered proven, the acquisition of the real property by the Claimant occurred in its capacity as creditor of the insolvent company, so one is before a situation whose economic substance is, moreover, identical to those of situations of payment in fulfillment of company property or assignment of property to creditors, which are expressly provided for in paragraph c) of no. 1 of the same article 270.º, as cases of exemption from IMT. In fact, no.1 of article 270º reinforces this interpretation, in that it results from it that, in cases where there occurs a payment in fulfillment of company property and assignment of property to creditors, such transactions are exempt from IMT. Now, the economic substance of these transactions in no way differs from that in which there occurs an acquisition of property of the insolvent by one of its creditors. Article 11º, no.3 of the JGT provides that "if doubt persists regarding the meaning of the rules of incidence to apply, the economic substance of the tax facts should be considered."

All elements of interpretation (literal, rational, systematic and even historical) converge in the direction of interpreting the provision of article 270º, no.2 of the CIRE, in conformity with the majority understanding of the jurisprudence mentioned above, that is, in the sense that the Claimant has the right to the exemption from IMT in the acquisition, within the framework of an insolvency process, of a real property belonging to the insolvent estate, of which it was a creditor, as results from the proven facts in the file.

1. Therefore, given all the foregoing, it appears that the correct interpretation of the provision of article 270º of the CIRE, as regards the exemption from IMT, in the acquisition of a real property belonging to the insolvent estate, by one of its creditors, imposes the recognition of this exemption. To which it further follows that, as already explained in the preceding points, between two meanings of the law, both with support – at least minimal – in its respective letter, the interpreter should opt for that which is compatible with its reason for being, with the economic substance underlying it and with the constitutional text (interpretation in accordance with the Constitution).

2. From all this it results that the challenged levy suffers from a defect of error regarding the prerequisites of law, consisting of a violation of article 270.º, no. 2, of the Code on Insolvency and Corporate Recovery, which imposes its annulment, with the consequent reimbursement to the Claimant of all amounts improperly paid, namely: the amount of the tax and surcharges, respectively, €33.844,75 and €695,29.

• Regarding the Request for Indemnity Interest

1. The Claimant also petitions for the condemnation of the AT for payment of indemnity interest.

Article 46.º of the Code on IMT provides as follows:

"1. Once the levy is annulled, either ex officio or by decision of the competent entity or tribunal, with res judicata, the respective reimbursement is effected.

1. (,,,)

2. Indemnity interest is due, under the terms of article 43.º of the General Tax Code that are levied and paid under the terms of the Tax Procedure and Process Code."

In accordance with the interpretation given to article 270.º, no. 2 of the CIRE, in this decision, IMT was not due, so such tax was improperly collected. Consequently, and without need for further reasoning, the Claimant has the right to indemnity interest, under the terms of the legal provisions mentioned above.

IV. DECISION

Therefore, this Arbitral Tribunal decides:

A) To render judgment upholding, as proven, the petition for arbitral pronouncement and, consequently, to declare illegal and to annul the act of levy of IMT, in the total amount of €34.540,04, corresponding to the value of tax and surcharges, respectively, €33.844,75 and €695,29, with the consequent obligation to reimburse the amounts improperly levied and paid by the Claimant;

B) To render judgment upholding the petition for payment of indemnity interest, counted from the date of improper payment until the date of processing of the respective credit note, as provided in no. 1 of article 43.º of the General Tax Code in conjunction with the provision of no. 5 of article 61.º of the Tax Procedure and Process Code.

C) To condemn the Respondent in the costs of this proceeding.

VALUE OF THE PROCEEDING

The value of the proceeding is fixed at €34.540,04 in accordance with article 97.º-A, no. 1, a), of the CPPT, applicable by virtue of paragraphs a) and b) of no. 1 of article 29.º of the RJAT and no. 2 of article 3.º of the Regulation of Costs in Tax Arbitration Processes.

COSTS

The value of the arbitration fee is fixed at €1.836,00 in accordance with Table I of the Regulation of Costs in Tax Arbitration Processes, to be paid by the unsuccessful party, under the terms of articles 12.º, no. 2, and 22.º, no. 4, both of the RJAT, and article 4.º, no. 4, of the cited Regulation.

Lisbon, 23 December 2016

Let it be notified.

The sole arbitral tribunal,

(Maria do Rosário Anjos)

[1] In the same sense, the following Judgments of the STA pronounced themselves: Judgment of 30-05-2012, in process no. 0949/11; of 17-12-2014, in process no. 01085/13; Judgment of 11-11-2015, in process no. 968/13; Judgment of 18-11-2015, in process no. 1067/15; of 18-11-2015, in process no. 575/15 and Judgment of 16-12-2015, in process no. 1345/15, all available at www.dgsi.pt.