Police and Tax Inspectors Search Banks and Law Firms Over Shelf Companies Allegedly Used to Dodge 66 Million Euros in Property Tax

The Polícia Judiciária (PJ, Portugal's criminal investigation police) and the Autoridade Tributária e Aduaneira (AT, the Tax and Customs Authority) carried out 53 searches on Wednesday morning in the Lisbon, Porto and Setúbal areas, in an investigation into an alleged scheme to avoid paying the tax due when property changes hands. The police estimate that the State lost more than 66 million euros between 2017 and 2025.

In a statement, the PJ said its national anti-corruption unit searched homes, companies, banks and law offices under three inquiries led by the Departamento Central de Investigação e Ação Penal (DCIAP, the Central Department of Criminal Investigation and Prosecution). The suspected offences are aggravated tax fraud ("burla tributária qualificada") linked to the improper use of the exemption from the Imposto Municipal sobre as Transmissões Onerosas de Imóveis (IMT, the municipal property transfer tax).

Which banks were searched

The PJ statement does not name the institutions. Correio da Manhã reported, and Observador and RTP confirmed, that Banco Carregosa, based in Porto, and Banco Angolano de Investimentos Europa (BAI Europa), in Lisbon, were among the places searched, along with property companies and law firms. A search does not mean that a bank or its managers are suspects. RTP reported that no arrest warrants were issued and that the operation was aimed at gathering evidence. We found no statement from either bank by late morning.

How the alleged scheme worked

According to the PJ, the investigation points to the organised creation, in series, of companies that were formally set up to buy and resell property but had no real business ("empresas de prateleira", or shelf companies). To make them look like habitual property traders, the suspects allegedly passed buildings back and forth between companies they controlled, "for derisory values" and "without any associated financial flow". On the strength of those transactions, the PJ says, the tax authority was led to recognise the companies' right to the IMT exemption.

The companies were then sold to Portuguese and foreign investors, who allegedly used them to buy property, including high-value portfolios of assets from banks, without paying the tax due.

The exemption at the centre of the case

Article 7 of the IMT Code exempts purchases of property bought for resale. A buyer who has declared the activity of buying property for resale normally still pays the tax up front, unless the authority recognises that the buyer does so "normally and habitually". Since Decreto-Lei n.º 49/2025, that is proven with a certificate from the Portal das Finanças (the tax portal) showing that the company resold property bought for that purpose in each of the two previous years. A record of resales between related shell companies would, on the PJ's account, have produced exactly that certificate.

The exemption is conditional. Under Article 11 of the Code, it lapses if the property is used for another purpose, is not resold within one year, or is sold on again for resale; the tax then becomes due from the date of purchase, with interest. The exemption is separate from the IMT relief for buyers under 35, which works on different rules (our guide explains it).

Who took part

The operation involved 103 PJ inspectors and 29 forensic specialists, 13 public prosecutors, three investigating judges, seven tax inspectors and a technical adviser from the Banco de Portugal (Bank of Portugal). The PJ said documents and items of "high evidential relevance" were seized, and that the investigation will continue under the DCIAP.

IMT is a municipal tax: its revenue goes to the local council where the property stands. The 2027 State Budget bill, now before parliament, separately proposes to extend IMT and IMI breaks on restored old buildings to 2031, as we reported on Monday.