Ten Northern Councils Press EDP and Movhera to Pay 335 Million Euros in Taxes on the 2020 Sale of Six Douro Dams
An open letter from ten Trás-os-Montes and Douro councils asks EDP and Movhera to pay the IMT, stamp duty and IMI they say is owed on six dams. Prosecutors put the sale's unpaid tax at 335.2 million euros; EDP says it will not pay until a court rules.
Ten councils in Trás-os-Montes and the Douro have written an open letter to the heads of EDP and Movhera, demanding that the two companies pay the taxes the councils say are owed on the 2020 sale of six hydroelectric dams, and stop fighting every bill in court. The letter, released on Monday 2 November, is addressed to EDP's chief executive, Miguel Stilwell de Andrade, and Movhera's, Beatriz Milne, Lusa reported via Notícias ao Minuto.
The signatories are Alfândega da Fé, Alijó, Carrazeda de Ansiães, Macedo de Cavaleiros, Miranda do Douro, Mirandela, Mogadouro, Murça, Torre de Moncorvo and Vila Flor. The dams in question are Miranda do Douro, Picote, Bemposta, Baixo Sabor, Feiticeiro and Foz Tua.
The 335 million euro bill
EDP sold the six dams for 2.2 billion euros at the end of 2020 to a consortium led by the French group Engie, which now runs them as Movhera. The sale was structured as a split of an EDP subsidiary followed by a sale of shares, rather than a direct sale of the dams. The Ministério Público (Public Prosecutor's Office) investigated it as possible tax fraud.
In an order of late 2025 closing that inquiry, prosecutors found no crime, but concluded that the tax-neutral treatment the parties had relied on did not apply, and that 335.2 million euros in taxes was owed, plus interest, Observador reported. The figure, calculated as of January 2025, breaks down as:
- about 114.7 million euros of IRC (corporate income tax) on EDP's gain from the sale;
- about 120.9 million euros of Imposto do Selo (stamp duty), in two parts of 108.6 million and 12.2 million;
- about 99.6 million euros of IMT (the municipal property transfer tax).
According to Observador, the stamp duty and the IMT are revenue due to the councils where the dams are. We set out the background to the dispute in August.
Where collection stands
In August, after warnings that the Autoridade Tributária (Tax and Customs Authority) was running out of time to issue the bills, the Ministry of Finance said the inspections, assessments and notifications "are already concluded or under way" and that the right to assess the taxes will not lapse, according to Observador and ECO. It said that if the taxes are not paid voluntarily, the tax authority will start enforced collection proceedings. The first assessment sent out was the 12.2 million euro share of stamp duty, Jornal de Negócios reported.
EDP disputes the bill. In May it said it agreed with neither the tax authority's reading nor its figures and "will not pay the assessments that are issued until the matter is resolved in court", Jornal de Negócios reported. EDP has said it complied with the tax rules.
The yearly IMI fight
The councils' letter also targets IMI (the municipal property tax) on the dams. They put the annual IMI assessed at 2,664,219 euros, which they say is about 0.13 percent of Movhera's turnover over five years: by the councils' count, the company billed 2.04 billion euros from the dams between 2021 and 2025. Movhera has contested the IMI bills. The Tribunal Administrativo e Fiscal de Mirandela (Mirandela Administrative and Tax Court) ruled against the company in five cases, and Movhera has appealed to the Tribunal Central Administrativo Norte (Central Administrative Court North), the letter says.
IMI on energy infrastructure is also in dispute elsewhere: as we reported on 27 October, a Constitutional Court ruling on how wind farms are valued threatens 266 council lawsuits over IMI on dams and turbines.
What the councils are asking
The letter puts six questions to the two chief executives, including whether they will help to settle all the taxes legally due on the sale and the running of the dams, and whether they will open "a genuine institutional dialogue" with the councils and adopt a stable social responsibility policy for the region. The councils say they do not question the companies' right to defend themselves in court, but reject "a relationship based on the endless prolonging of disputes at the expense of local people".
"What the ten councils want with this open letter is to make sure they receive their rightful taxes from the sale of the six dams, and that there is fiscal and territorial justice," José Meneses, the mayor of Torre de Moncorvo and the councils' spokesperson, told Lusa.
For the councils, the sums dwarf their yearly IMI from the dams: the IMT and stamp duty identified by prosecutors come to about 220 million euros, against about 2.7 million euros a year in IMI. We found no public reply from EDP or Movhera to the letter by Monday night.
