Summary
Full Decision
ARBITRAL DECISION
I – 1. REPORT
A… – CLOSED REAL ESTATE INVESTMENT FUND, with NIPC…, managed and represented by B…, S.A., with headquarters at Avenue …, no.…, …, in Lisbon and with NIPC… (hereinafter referred to as Claimant), hereby requests, pursuant to the combined provisions of articles 2, no. 1, paragraph a) and 10, nos. 1 and 2, of Decree-Law no. 10/2011, of 20 January, which approved the Legal Framework for Arbitration in Tax Matters (RJAT), the constitution of an Arbitral Tribunal, with the intervention of a sole arbitrator, in which the Tax and Customs Authority (hereinafter, AT or Respondent) is the defendant, with a view to the declaration of illegality and consequent annulment of the assessment of Stamp Tax (Item 28.1, of the General Table of Stamp Tax), relating to the year 2015, in the total amount of €58,233.11 (fifty-eight thousand, two hundred and thirty-three euros and eleven cents), of which it was notified through collection notes nos. 2016…, for voluntary payment of the first instalment in April 2016; 2016…, for voluntary payment of the second instalment in July 2016 and 2016…, for voluntary payment of the third instalment in November 2016.
The Claimant further requests that the Respondent be ordered to reimburse the amounts unduly paid or to be paid in relation to the disputed assessment, as well as the payment of compensatory interest, in accordance with legal provisions.
I – 2. Summary of the Parties' Positions:
a. Of the Claimant
As grounds for its claim, the Claimant invokes the following:
1. The Stamp Tax assessment – item 28.1, of the General Table of Stamp Tax, which is being contested, relates to the urban property registered in the matrix under article … of the parish of …, municipality and district of Lisbon, described as "land for construction";
2. Law no. 55-A/2012, of 29 October, introduced various amendments to the Personal Income Tax Code, the Corporate Income Tax Code, the Stamp Tax Code and the General Tax Law, aimed at establishing measures "(…) fundamental to reinforcing the principle of social equity in austerity, ensuring an effective sharing of the sacrifices necessary to fulfil the adjustment programme (…)", as per the Draft Law no. 96/XII/2nd presented by the Government to the Parliament;
3. Among other amendments, Law no. 55-A/2012, of 29 October, added item 28 to the General Table of Stamp Tax, through which the Government intended to institute a special taxation on urban properties with a value exceeding €1,000,000.00, an index of high taxpaying capacity;
4. With the amendments introduced to item 28 of the General Table of Stamp Tax by Law no. 83-C/2013, of 31 December, the taxable event was extended to the ownership of rights of "property, usufruct or right of superficies" of land for construction with taxable property value exceeding €1,000,000.00, which has "a building for construction", "authorised or envisaged";
5. Although the property subject to the Stamp Tax assessments sub judice is registered in the matrix as "land for construction", it cannot be subsumed into the concept of "properties with residential use" and, consequently, is not included within the scope of the objective incidence of item 28 of the General Table of Stamp Tax, since "the taxation in question shall only apply in situations where the effective construction of the 'land' has been authorised or envisaged in the specific case and such construction is intended for 'residential use'" (see article 25, of the grounds);
6. However, the property in question did not have, in the year to which the tax relates, nor does it currently have, any "building, authorised or envisaged" for "residential use", as required by item 28.1 of the General Table of Stamp Tax (article 34, of the grounds);
7. It does not even have "any (valid) construction licence/authorisation or any (approved) project" (article 35, of the grounds), as the Claimant does not intend to allocate the property to any type of construction or urban development project, being intended, within the scope of its activity, to be resold in the exact terms in which it was acquired;
8. Given the foregoing, the Claimant considers it evident that the Stamp Tax assessment of the year 2015 is manifestly illegal, due to error in the facts and law presuppositions, and should be promptly annulled, as has been decided in similar cases by various Arbitral Decisions;
9. As a subsidiary argument, the Claimant invokes the unconstitutionality of item 28.1 of the General Table of Stamp Tax, when applied to "land for construction", for violation of the principle of equality, enshrined in article 13 of the Constitution of the Portuguese Republic and of the principles of tax equality and taxpaying capacity, enshrined in no. 3 of article 104 of the constitutional text (articles 49 and following, of the grounds);
10. That, notwithstanding the Constitutional Court having already ruled, notably in Decisions nos. 590/2015, of 11 November and 692/2015, of 16 December, for the non-unconstitutionality of the norm of item 28.1 of the General Table of Stamp Tax, such case law does not apply to the case at hand, inasmuch as in those proceedings the issue was the application of the norm to "residential properties", a situation distinct from that of "land for construction, whose building, authorised or envisaged, is for residential use, with a taxable property value equal to or exceeding €1,000,000.00" (articles 98 and following, of the grounds).
The Claimant concludes by manifesting the intention not to appoint an arbitrator and formulating the requests for (a) annulment of the disputed assessment, with (b) the reimbursement of unduly paid tax (or to be paid), (c) increased by compensatory interest, in accordance with article 43, no. 1, of the General Tax Law and 61, of the Tax Procedure and Process Code.
b. Of the Respondent:
Notified in accordance with the terms and for the purposes provided in article 17 of the RJAT, the AT submitted a reply, stating that it is of the opinion that the Claimant's claim is not well-founded, on the following grounds:
1. Upon consultation of the certified copies of the documents that gave rise to the disputed assessment, it is verified that the property in question is land for construction to which residential use has been assigned, both within the scope of the respective valuation and in the registration, and is therefore subject to Stamp Tax;
2. Tax law considers as an integrating element, for the purposes of assessing land for construction, the value of the implantation area, which varies between 15% and 45% of the value of authorised or envisaged buildings, based on the urban planning and construction project, and it cannot be ignored that the licensing permit for the carrying out of urban development operations contains, among other elements, the number of lots and the indication of the location area, purpose, implantation area, construction area, number of storeys and number of units in each of the lots, with specification of units intended for subsidised housing, where envisaged, in accordance with paragraph a) of article 77 of the Urban Development Operations Regulation;
3. With Law no. 83-C/2013, of 31 December, item 28.1 of the General Table of Stamp Tax now reads as follows: "28.1 – For residential property or for land for construction whose building, authorised or envisaged, is for residential use, in accordance with the provisions of the Real Estate Tax Code – 1%", with the legislator limiting itself to defining, "«without any margin for doubt», the logical element underlying the explanatory memorandum that served as the basis for Draft Law no. 96/XII (…)", of "promoting the expansion of the tax base, requiring an increased effort from taxpayers with higher income…";
4. Taxation through item 28 of the General Table of Stamp Tax complies with the criterion of suitability, in that it aims at wealth embodied in the ownership of properties of high value, seeking maximum efficiency in the collection of revenue, with a minimum of harm to other relevant interests, and is not in violation of the principle of proportionality;
5. Nor does it appear to violate the principle of equality or taxpaying capacity, as it applies indiscriminately "to all holders of properties with residential use with a value exceeding €1,000,000.00";
6. Furthermore, the Administration acts in strict compliance with the law, within the limits of the powers conferred upon it, and does not have the authority to decide on the non-application of norms regarding which doubts of constitutionality may arise, a task that falls to the courts, in accordance with article 204 of the Constitution of the Portuguese Republic;
7. The right to compensatory interest, due to judicial annulment of an assessment act, depends on the demonstration that the act results from error attributable to the administration, from which results payment of the tax in an amount exceeding that legally due;
8. The disputed assessment was carried out on the basis of applicable law to which the Administration is bound; the error upon which the right to compensatory interest depends is only that which is concretised in the defective appreciation of the facts or in the incorrect application of legal norms, and is not payable when it is a matter of the application of a norm that subsequently comes to be judged unconstitutional.
The AT concludes by requesting the waiving of the meeting provided for in article 18 of the RJAT, declaring the intention not to submit further arguments, given that the issue to be decided depends exclusively on the interpretation of the norm of item 28 of the General Table of Stamp Tax, and no exceptions have been invoked that would prevent proceeding directly to the decision of the case.
As part of the administrative procedure, there was sent to the file the e-mail no. …/2016, of DSIMT – Directorate of Services for Real Estate Transfer Tax, Stamp Tax, Unique Circulation Tax and Special Contributions, dated 5 September 2016, with content that, in part, is transcribed as follows: "(…) It is hereby informed that there are no administrative proceedings in this Directorate relating to the procedure in question. The procedure for the assessment of tax stems from the automatic processing of assessments, based on matrix information and the application of the law to the facts, such that the elements underlying the assessment may be obtained directly from the automated assessment system.
As regards the substantive matter – incidence of Stamp Tax – Item 28 of the General Table of Stamp Tax, relating to plots of land for construction with residential use, this Directorate maintains the understanding, which results from the applicable legal norms, namely, no. 6 of article 1 of the Stamp Tax Code.".
II – PROCEDURAL MATTERS
1. The request for the constitution of the Arbitral Tribunal was filed with the CAAD on 28 July 2016, having been accepted by the Honourable President of the CAAD and automatically notified to the AT;
2. Pursuant to no. 1 of article 6 of the RJAT, the undersigned was appointed as arbitrator by the Honourable President of the Deontological Council of the CAAD, a responsibility which she accepted within the legally prescribed period, without opposition from the Parties;
3. The Singular Arbitral Tribunal was properly constituted on 19 October 2016 and has material jurisdiction to appreciate and decide the dispute at issue in the present proceedings;
4. The Parties have legal personality and capacity, are properly interested and are duly represented (articles 4 and 10, no. 2, of the RJAT and article 1 of Ordinance no. 112-A/2011, of 22 March);
5. The proceedings do not suffer from any defects and no exceptions were invoked;
6. The Parties dispensed with the holding of the meeting alluded to in article 18 of the RJAT, as well as with the production of arguments, whether oral or written.
III. GROUNDS:
III.1. FACTS
A) Facts considered proven:
The Tribunal's conviction as to the factual matter below, which is considered proven, resulted from critical analysis of the documentary evidence attached to the request for arbitral pronouncement (copies of the property record card and payment collection notes for the Stamp Tax assessment of 2015):
1. The Claimant appears as the registered owner in the matrix of the urban property registered under article … of the parish of …, municipality of Lisbon, described there as "land for construction", with total area of 13,297.0000 m², the implantation area of the building being 5,017.0700 m², the gross construction area of 15,051.2000 m² and the dependent gross area of 0.0000 m²;
2. In the valuation carried out on 24 January 2011 (valuation sheet no.…), based on the Model 1 declaration for Real Estate Tax no.…, delivered on 14 January of the same year, the Ca (use coefficient referred to in article 41 of the Real Estate Tax Code) of 1.00 – residential use was considered, and the type of location coefficient for calculating the implantation area was also residential use;
3. The current taxable property value of the property, determined in 2014, which served as the basis for the disputed assessment, is €5,823,311.33;
4. The Claimant was notified to proceed with payment of the Stamp Tax assessment – item 28.1 of the General Table of Stamp Tax, issued by the AT on 05/04/2016, by reference to the year 2015 and the identified property, in the global amount of €58,233.11, in three instalments, the first in the amount of €19,411.05, to be paid in April 2016; the second and third in the amount of €19,411.03 each, to be paid in July 2016 and November 2016, respectively;
5. The Claimant proceeded with the payment of the first and second instalment of the assessed tax.
B) Facts not proven
The existence of an authorisation or building licence for residential construction on the identified plot of land was not proved, nor that the Claimant had paid the third instalment of the disputed Stamp Tax assessment.
III.2 MATTERS OF LAW
The questions to be decided:
The questions to be decided in the present proceedings are as follows:
a) Whether an urban property registered in the matrix as "land for construction", in the valuation of which the location and use coefficients for "residential use" were taken into account and which has been assigned a taxable property value (VPT) exceeding €1,000,000.00, is covered by the scope of incidence of item no. 28.1 of the General Table of Stamp Tax, as amended by Law no. 83-C/2013, of 31 December, even if it did not have, in the year to which the tax relates, any "building, authorised or envisaged" for "residential use", nor "any (valid) construction licence/authorisation or any (approved) project";
b) If the answer is negative, whether the assessment issued by the AT in relation to such property for the year 2015 is vitiated by the defect of violation, due to error in the factual and legal presuppositions, or whether its illegality is based on the unconstitutionality of the norm of item 28.1 of the General Table of Stamp Tax, as requested subsidiarily by the Claimant, and
c) Whether, if the assessment comes to be annulled, compensatory interest is owed on the amounts that were unduly paid.
In accordance with no. 1 of article 124 of the Tax Procedure and Process Code, of subsidiary application to the tax arbitral process, pursuant to article 29, no. 1, paragraph a), of the RJAT, in the absence of defects that lead to the declaration of non-existence or nullity of the contested act, the tribunal should appreciate the defects alleged that determine its voidability, and no. 2, paragraph b) of the same article provides that, as regards the latter, the order of their appreciation shall be that indicated by the claimant, whenever a relationship of subsidiarity is established between them.
As follows from the request for arbitral pronouncement, the claim for annulment of the disputed assessment, on the ground of unconstitutionality of the incidence norm, is of a subsidiary nature, and, as rightly noted by the Respondent, the Administration must act in compliance with the law, within the limits of the powers conferred upon it, that is, in principle, the Administration, according to "the traditional solution (moreover, the most in accordance with the constitutional system) (…)" (…) "in principle (…) is immediately subordinate to the law, and cannot fail to comply with it on the pretext of its unconstitutionality."[1].
Thus, as it appears that from the success of the defect of violation of law will result effective protection of the injured interests, as it is preventative of the renewal of the contested act, we shall immediately proceed to its appreciation.
Of the concept of "land for construction whose building, authorised or envisaged, is for residential use".
Item 28 of the General Table of Stamp Tax, as amended by Law no. 83-C/2013, of 31 December (State Budget for 2014), applicable to the matter in dispute in the present proceedings, establishes the subjection to Stamp Tax of the following situations:
«28 – Ownership, usufruct or right of superficies of urban properties whose taxable property value registered in the matrix, in accordance with the Real Estate Tax Code (CIMI), is equal to or greater than (euro) 1,000,000 - on the taxable property value used for the purpose of Real Estate Tax:
28.1 – For residential property or for land for construction whose building, authorised or envisaged, is for residential use, in accordance with the provisions of the Real Estate Tax Code – 1%
28.2 – For property, when the taxpayers who are not individuals are resident in a country, territory or region subject to a clearly more favourable tax regime, listed in an ordinance approved by the Minister of Finance – 7.5%.»
Thus, there are cumulative requirements for the application of the incidence norm of Item 28.1 of the General Table of Stamp Tax, in the wording in force for the year 2015 and with regard to land for construction, that for the latter there be "a building, authorised or envisaged", intended for "residential use" and that its taxable property value, for the purpose of Real Estate Tax, be equal to or greater than €1,000,000.00.
Although the Stamp Tax Code does not contain a definition of what constitutes "land for construction, whose building, authorised or envisaged, is for residential use", the interpreter, for the determination of the exact meaning and scope of the expression contained in the incidence norm and in respect for the unity of the system, should have recourse to the so-called "parallel places", that is, account must be taken of "legal provisions that regulate parallel normative issues or related institutes"[2].
Such "parallel places" will necessarily be found, in the case at hand, in the norms of the Real Estate Tax Code, by the generic referral of no. 6 of article 1 of the Stamp Tax Code, and specifically, both by no. 2 of article 67 of the same Code, as amended by Law no. 55-A/2012, of 29 October, and also by the norm itself of item 28.1 of the General Table of Stamp Tax, which refer to that Code.
The concept of land for construction is defined in article 6 of the Real Estate Tax Code – Types of urban properties, according to whose no. 1, urban properties may be a) Residential, b) Commercial, industrial or for services, c) Land for construction, and d) Other, and no. 3 of the same article provides that "3 - Land for construction shall be considered to be plots of land located within or outside an urban settlement, for which a licence or authorisation has been granted, prior notification admitted or favourable prior information issued for a subdivision or construction operation, and also those which have been declared as such in the acquisition deed, except for land where the competent authorities prohibit any of those operations, namely those located in green areas, protected areas or which, in accordance with municipal spatial planning plans, are allocated to public spaces, infrastructure or facilities".
However, not all land for construction is intended to be built for residential purposes, and even those registered in the matrix under that classification may cease to meet the conditions for such, as clearly explained by António Santos Rocha and Eduardo José Martins Brás, in annotation to no. 3 of article 6 of the Real Estate Tax Code, when they write that "Properties already described in the matrix as land for construction, regarding which the lapse of the subdivision, licence or construction authorisation has occurred and in which no construction operation has even been initiated, must, by means of the aforementioned institute of lapse, recover their former nature (…)".[3]
Even with regard to land for construction registered in the matrix on the basis of declarations presented by taxpayers, as, in accordance with the property record card attached to the request for arbitral pronouncement, would appear to have been the case with the land subject to the disputed Stamp Tax assessment, the aforementioned Authors consider that, given that such declarations do not have constitutive effect, there is "the necessity of the existence of identification of the document authorising the construction or the subdivision." And that, "If the omission of the indication of that document subsists, the services must resort to the expedient provided for in article 128 [of the Real Estate Tax Code] and contact the respective Municipality".[4]
This annotation by the Authors is well understood, as it is the Municipal Councils that are the bodies issuing subdivision permits, building licences, demolition and works permits and holders of the other elements that permit the correct registration of properties, and registration matrices, as a record of the characterisation thereof, whose organisation and maintenance are the responsibility of the finance services where the properties are located (article 78, no. 1, of the Real Estate Tax Code), should be "updated annually with reference to 31 December", as provided in no. 4 of article 12 of the Real Estate Tax Code, as this is the date on which the taxable event is produced, both in the context of Real Estate Tax and of Stamp Tax Item 28.1 of the General Table of Stamp Tax.
If, on 31 December of each year, the registration matrix is not updated so as to reflect the exact characteristics of the property, on which depends the fulfilment of the presuppositions of the incidence norm, the property cannot be subject to the taxation provided for therein.
3. On the merits of the disputed assessment:
In the request for arbitral pronouncement, the Claimant invokes, as a ground for the error regarding the factual presuppositions upon which the disputed assessment is based, that the property in question did not have, in the year to which the tax relates, nor does it currently have, any "building, authorised or envisaged" for "residential use", as required by item 28.1 of the General Table of Stamp Tax.
In accordance with the respective property record card, with a copy attached to the file, the urban property of which the Claimant is the owner, described as land for construction with location and use coefficients relating to residential use, was valued and registered in the matrix on the basis of the Model 1 declaration, referred to in article 13 of the Real Estate Tax Code, presented on 14 January 2011 (Model 1 declaration no.…), and the property record card contains no reference to any other elements that would permit the classification of the property as "land for construction whose building, authorised or envisaged, is for residential use", characteristics which constitute the presuppositions for the application of the norm of Item 28.1 of the General Table of Stamp Tax.
Nor, for that matter, does the administrative procedure embodied in e-mail no. 1978/2016 of DSIMT, dated 5 September 2016, annexed to the AT's Reply, according to which "The procedure for the assessment of tax stems from the automatic processing of assessments, based on matrix information and the application of the law to the facts, such that the elements underlying the assessment may be obtained directly from the automated assessment system", constitute proof that the property of the Respondent possesses the requirements that would permit its inclusion within the scope of that incidence norm.
In fact, proof has the function of demonstrating the reality of the facts upon which the right sought to be established is based, and no. 1 of article 74 of the General Tax Law – "Burden of proof" determines that "1 – The burden of proof of the constitutive facts of the rights of the tax administration or of the taxpayers falls upon whoever invokes them".
As a corollary of the rule on the burden of proof of constitutive facts, the proof of facts that impede the AT's right to collect the assessed tax revenue would always fall upon the AT itself, in accordance with what is established in no. 2 of article 342 of the Civil Code, as such proof "falls upon the one against whom it is invoked".
Thus, given that the Claimant has invoked the non-existence of "(valid) construction licence/authorisation or any (approved) project" and the AT has not presented to the arbitral tribunal any proof of its existence, it must be concluded that it cannot be considered proven that the land in question has "building, authorised or envisaged, for residential use", in accordance with the Real Estate Tax Code.
And, given that the actual possibility of construction for the purposes provided for in item 28.1 of the General Table of Stamp Tax has not been demonstrated, there is no other conclusion to be drawn than that the Stamp Tax assessment carried out by the AT is illegal, as the factual and legal presuppositions upon which the application of that incidence norm depends are not met, an error exclusively attributable to the Respondent, which issued such assessment without legal authority to do so.
Anticipating the decision, it may be said that, for the reasons set out above, the request for arbitral pronouncement should be judged entirely well-founded, and the disputed assessment cannot remain in the legal order.
4. As to the requests for reimbursement of amounts paid and compensatory interest
In accordance with the provisions of article 24 of the RJAT, article 100 of the General Tax Law determines, applicable to the tax arbitral process by virtue of the provisions of paragraph a) of no. 1 of article 29 of the RJAT, that "The tax administration is obliged, in case of total or partial success of complaints or administrative appeals, or of judicial proceedings in favour of the taxpayer, to immediately and fully restore the situation that would have existed if the illegality had not been committed, including the payment of compensatory interest, in accordance with the terms and conditions provided by law.".
"Immediate and full restoration of the situation that would have existed if the illegality had not been committed" implies, first and foremost, the reimbursement of the amounts unduly paid, relating to the tax act totally or partially annulled, whether through the administrative or judicial route, and may further comprise the indemnification of the taxpayer for damages resulting from the undue payment, through the payment of compensatory interest, in accordance with terms legally established.
Having the tax arbitral process been conceived as an alternative means to judicial impugnation proceedings (see the legislative authorisation granted to the Government by article 124, no. 2 (first part) of Law no. 3-B/2010, of 28 April – State Budget Law for 2010), it should be understood that the powers which, in judicial impugnation proceedings, are conferred on tax courts, such as that of appreciating error attributable to the administration, the source of the obligation to indemnify, are included in the competence of the arbitral tribunals functioning under the aegis of the CAAD.
Error attributable to the administration may consist of error regarding the factual presuppositions or the legal presuppositions and "is demonstrated when they proceed with an administrative complaint or judicial impugnation of the same assessment and the error is not attributable to the taxpayer"[5].
In the case at hand, it appears manifest that, with the declaration of the illegality of the Stamp Tax assessment of the year 2015, which justifies its annulment, and the demonstration of the AT's error in the application of the incidence norm, the Claimant's right to compensatory interest must be recognised, in accordance with no. 1 of article 43 of the General Tax Law, as such illegality is exclusively attributable to the AT, which carried out the tax act without the necessary legal support.
Questions of impeded cognition
In the sentence, the judge must pronounce upon all questions he should appreciate, refraining from pronouncing upon questions he should not know (final segment of no. 1 of article 125 of the Tax Procedure and Process Code), and the questions upon which the tribunal's cognition powers fall are, in accordance with no. 2 of article 608 of the Code of Civil Procedure, applicable subsidiarily to the tax arbitral process, by referral of article 29, no. 1, paragraph e) of the RJAT, "the questions which the parties have submitted to its appreciation, except those whose decision is impeded by the solution given to others (…)".
Having recognised the illegality of the Stamp Tax assessment – item 28.1 of the General Table of Stamp Tax, due to error in the factual and legal presuppositions, the appreciation of the remaining questions raised by the Parties is impeded, namely that of the possible unconstitutionality of the norm cited.
IV. DECISION
For the reasons set out above and, pursuant to article 2 of the RJAT, the decision is rendered, judging the present request for arbitral pronouncement entirely well-founded:
a. To declare the illegality of the Stamp Tax assessment disputed due to error in the factual and legal presuppositions, determining its annulment;
b. To order the AT to reimburse the amounts unduly paid by the Claimant as Stamp Tax for the year 2015, plus compensatory interest, from the date of each payment until the date of issuance of the respective credit note.
VALUE OF THE PROCEEDINGS: In accordance with the provisions of article 306, nos. 1 and 2, of the Code of Civil Procedure, 97-A, no. 1, paragraph a), of the Tax Procedure and Process Code and 3, no. 2, of the Regulation of Costs in Tax Arbitration Proceedings, the value of the proceedings is fixed at €58,233.11 (fifty-eight thousand, two hundred and thirty-three euros and eleven cents).
COSTS: Calculated in accordance with article 4 of the Regulation of Costs in Tax Arbitration Proceedings and Table I annexed thereto, in the amount of €2,142.00 (two thousand, one hundred and forty-two euros), to be borne by the Tax and Customs Authority.
Lisbon, 15 December 2016.
The Arbitrator,
/Mariana Vargas/
Text prepared by computer, pursuant to no. 5 of article 131 of the Code of Civil Procedure, made applicable by referral of paragraph e) of no. 1 of Decree-Law 10/2011, of 20 January.
The drafting of this decision complies with the 1990 Orthographic Agreement.
[1] See Gomes Canotilho and Vital Moreira, "Constitution of the Portuguese Republic" Annotated, Vol. II – 4th Edition, Coimbra Editor, 2014, p. 800.
[2] MACHADO, J. Baptista, "Introduction to Law and to Legitimising Discourse", Almedina, Coimbra, 1995, p. 183.
[3] See the Authors cited, "Taxation of Wealth", Almedina, Coimbra, 2015, p. 46.
[4] Ibid.
[5] CAMPOS, Diogo Leite de, RODRIGUES, Benjamim Silva, SOUSA, Jorge Lopes de "General Tax Law – Annotated and Commented", Escritura Meeting, 4th Edition, p. 342.
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