The tax implications of any arrangements or transactions will not be recognized if the principal purpose, or one of the principal purposes, of those arrangements or transactions is to reduce, defer, or exempt from tax.
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July 23, 2026
Ministerial Decision No. 55 of 2025, implementing Decree-Law No. 157 of 2024, establishes a key anti-avoidance provision in Article 101. This article grants the Tax Administration authority to disregard transactions or arrangements where a principal purpose is tax reduction, deferral, or exemption. The Administration will evaluate the arrangement's genuine commercial or economic rationale, its method of execution, and the consistency between its legal form and economic substance. This rule ensures that tax outcomes align with underlying economic reality, preventing artificial structures designed to circumvent the DMTT.
CHAPTER 15 - TAX AUDIT AND ASSESSMENT
Article 101 - Anti-tax Avoidance
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