Pratice Areas Tax Law
Property Taxes
We support companies, individuals, and family groups within the scope of property taxes, namely through the integrated management of IMI, IMT, AIMI, and Stamp Duty, intervening from planning to administrative and judicial defense.
Property taxes decisively influence the structuring of real estate investments, the organization of family wealth, and the use of special purpose vehicles (SPVs).
Each decision to acquire, transfer, finance, or reorganize ownership can generate significant tax impacts, both at the time of the transaction and over time, especially when there is no integrated planning in the context of property taxes such as IMI, IMT, AIMI, and Stamp Duty.
Our intervention focuses on this integrated analysis, evaluating the combination of applicable taxes, the allocation of real estate, and the ownership structure. In coordination with notaries, financial institutions, brokers, and internal teams, we work to ensure that the legal solution is coherent with investment, succession, and financing objectives.
Faced with mismatched valuations, additional assessments, or rejections of exemptions, we reconstruct the case and consider the use of available administrative and litigation remedies, treating property taxes as a planned element of the client's global strategy, rather than an unexpected cost.
Services
We help individual clients, family groups, and companies define efficient property tax strategies, considering investment, transfer, succession, or business allocation objectives. We analyze the ownership structure, allocation to primary residence, letting, or economic activity, and the combined impacts of IMI, IMT, AIMI, and Stamp Duty.
We simulate scenarios of purchase, sale, donation, usufruct, asset divisions (partilhas), or corporate restructurings, and we help choose the most tax-efficient solution. Our intervention begins before the investment decision, accompanies the contractual documentation, and continues after the transaction, adjusting the strategy according to changes in the legal framework or the family and business context.
In the field of IMI, we provide support from analyzing the taxable property value (valor patrimonial tributário - VPT) to assessing the potential applicability of exemptions. We verify whether the property meets the conditions for temporary exemptions associated with primary and permanent residence or residential letting, or exemptions linked to low income and low VPT.
We support the preparation of exemption requests, review of valuations, correction of areas and allocations, and challenging undue assessments. For corporate real estate portfolios, we build asset-by-asset IMI maps, identify properties, and coordinate with accounting and asset management teams to ensure compliance regarding property taxes.
Regarding IMT, we frame transactions based on the property's purpose—whether primary permanent residence, secondary residence, or investment—location, typology, and potential exemption regimes.
We support negotiations with banks, notaries, and brokers, ensuring that the deal structure accurately reflects the economic reality and mitigating the risks of subsequent corrections. Whenever necessary, we contest additional assessments or rejections of exemptions.
Stamp duty is often overlooked in the structuring of real estate deals, but it can have a significant impact, as it applies to almost all acts, contracts, and financial transactions. In this scope, we structure financing operations, guarantees, and restructurings to anticipate Stamp Duty incidence and avoid unnecessary charges.
From the negotiation phase, we identify potentially taxed acts, compare contractual alternatives, and map out Stamp Duty impacts. We audit promissory contracts, deeds, and intra-group operations, and represent clients in disputes whenever differences arise with the Tax Administration.
For larger portfolios, we evaluate exposure to AIMI (Additional Municipal Property Tax), apply deductions, verify VPT, and analyze alternative ownership or allocation options in compliance with the law. We prepare requests for framing corrections, AIMI reviews, and defense in additional assessment proceedings.
The goal is for AIMI to be a known, managed factor integrated into the wealth management strategy, rather than an expensive end-of-year surprise.
Our approach
Advance planning
We structure real estate and corporate operations regarding property taxes, mitigating costs and maximizing tax benefits.
Integrated analysis
We evaluate the combined impacts of IMI, IMT, AIMI, and Stamp Duty, avoiding isolated and inefficient decisions.
Technical defense
When undue valuations or assessments arise, we prepare administrative appeals, reviews, and litigation.
FAQs
Because every decision to buy, sell, donate, or reorganize corporate structures can trigger different consequences regarding IMI, IMT, AIMI, and Stamp Duty, often simultaneously. Advance planning avoids unnecessary costs and reduces the risk of additional assessments or rejections of benefits.
We analyze whether the property meets the conditions for exemptions linked to primary and permanent residence, residential letting, or low-income situations with low VPT. We support the preparation of the IMI exemption request, the review of valuations, and the challenging of unfavorable decisions for the taxpayer.
Whenever you are acquiring a property for primary residence, investment, or economic activity. We frame the property's purpose, value, and location, verify if there are applicable benefits or exclusions, and assess the impact of the IMT rate on the overall deal structure before signing promissory contracts or deeds.
We map out the entire portfolio of properties, verify their VPT, allocations, and ownership (individuals, couples, or corporations), and simulate different scenarios. From there, we design legal strategies to manage AIMI as a known and controlled cost, rather than an annual surprise.
Because it applies not only to the transfer of the property itself but also to financing contracts, guarantees, capital reinforcements, and other associated acts. We identify early on where Stamp Duty may arise, compare contractual alternatives, and structure operations to avoid unnecessary charges.
Yes. We analyze the use of corporate vehicles in light of IMI, IMT, AIMI, and Stamp Duty, as well as succession and financing objectives. We simulate different ownership and allocation structures so that the chosen option is tax-efficient and legally stable.
We reconstruct the case, check for factual or legal errors, and define the best path of reaction: a request for valuation review, an administrative appeal (reclamação graciosa), an ex-officio review (revisão oficiosa), or judicial litigation. The goal is to correct undue assessments and recover what has been overpaid.
We work with families and their consultants to align donations, usufructs, asset divisions, and corporate reorganizations with their impact on IMI, IMT, AIMI, and Stamp Duty. The focus is to enable the transfer of wealth with controlled and predictable costs.
We cover the entire cycle: prior planning, negotiation, formalization with notaries and banks, and later, the monitoring of valuations, assessments, and exemption opportunities. We adjust the strategy whenever the legal framework or the family and business context changes.
Before deciding to buy, sell, donate, finance, or restructure real estate or property-holding companies. In this phase, it is still possible to choose the least burdensome path; once contracts are signed and assessments are issued, the room for maneuver reduces drastically.