Portugal’s Judicial Police (Polícia Judiciária, PJ) and Tax and Customs Authority (Autoridade Tributária, AT) carried out 53 searches across Lisbon, Porto and Setúbal on October 14, under an operation named “Tax Free.” Among the locations searched were the headquarters of two banks, Banco Carregosa in Porto and Banco Angolano de Investimento (BAI) in Lisbon, alongside private homes, companies and law firms. In an official statement, the PJ said investigators suspect an organized scheme involving the serial creation of “shell companies” — formally set up to buy and resell property but with no real economic activity — used to obtain exemptions from Portugal’s Municipal Property Transfer Tax (IMT) in cases where the tax should have been paid.
The companies allegedly involved are not the target buyers themselves: investigators believe the shell companies were marketed and sold on to Portuguese and foreign investors, who then used them to acquire property — including portfolios of high-value assets and bank-owned property — without paying the IMT due. For overseas buyers active in the Portuguese market, the relevant exposure is less about any one transaction and more about counterparty due diligence: the case underlines why a company’s prior ownership history and the basis of any IMT exemption claimed on a property being purchased are worth verifying before a deal closes, rather than assumed from paperwork alone.
Under IMT rules, a company can qualify for an exemption from the tax if it can show it resold at least one property in each of the two prior years, demonstrating genuine buy-to-resell activity. The PJ says the suspects instead simulated that activity: properties were repeatedly transferred between companies they controlled, for nominal sums and without real payment changing hands, to create the appearance of normal resale business and qualify for exemptions the companies were not entitled to. The suspected offences span 2017 to 2025 and may constitute aggravated tax fraud; the PJ estimates the resulting loss to the Portuguese state at more than €66 million. The operation, led by the Central Department for Investigation and Criminal Prosecution (DCIAP), involved 103 PJ inspectors, 29 forensic police specialists, 13 public prosecutors, three investigating judges and a technical adviser from the Bank of Portugal (Banco de Portugal).
DCIAP has confirmed the case is under judicial secrecy, meaning further details about the suspects and the evidence gathered are not being made public for now. No timeline for charges or further disclosures has been given by the named authorities.
References
Portugal Resident – Police search two banks in €66 million property tax fraud investigation / Observador – Buscas no Banco Carregosa e no Banco Angolano de Investimentos
