Opinion of the Advocate General — ECLI:EU:C:2026:93
Date: 2026-02-12
Language of the case: Portuguese

Translation C-837/24 – 1 
Case C-837/24 
Request for a preliminary ruling 
Date lodged: 
6 December 2024 
Referring court: 
Tribunal Arbitral Tributário (Centro de Arbitragem 
Administrativa – CAAD) (Portugal) 
Date of the decision to refer: 
3 December 2024 
Applicant: 
NOVA IBEROMOLDES – SGPS, S.A. 
Defendant: 
Autoridade Tributária e Aduaneira 
  
[…] 
ARBITRATION AWARD 
REQUEST FOR A PRELIMINARY RULING 
The arbitrators […], who make up the arbitration panel constituted in the case 
identified above, decide as follows: 
I. DETAILS OF THE PARTIES 
1 Applicant: NOVA IBEROMOLDES – SGPS, S.A., […] having its registered 
office […] [in] Lisbon (‘the applicant’). 
2 Defendant: Autoridade Tributária e Aduaneira (Tax and Customs Authority, 
Portugal; ‘the TCA’). 
EN 
REQUEST FOR A PRELIMINARY RULING OF 3. 12. 2024 – CASE C-837/24 
 
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II. MAIN PROCEEDINGS 
2.1. Subject matter of the main proceedings 
3 On 22 September 2023, the applicant requested the constitution of the Tax 
Arbitration Tribunal and filed a request for arbitration, seeking a declaration of the 
unlawfulness of, and, consequently, the annulment of, the supplementary 
assessment in respect of the Imposto Municipal sobre [as Transmissões Onerosas 
de] Imóveis (municipal tax on transfers of immovable assets for value; ‘IMT’), for 
the amount of EUR 79 880.06, made by the TCA in the context of the corporate 
restructuring of the group of which the applicant forms part. 
4 The share capital of the applicant (incorporated on 28 March 2019) was fully paid 
up by means of non-cash contributions, consisting of holdings or shares which its 
sole shareholder – Iberomoldes, SGPS S.A. – had in various companies. One of 
those companies, ‘Edilásio Carreira da Silva Lda.’ (limited company), the share 
capital of which is now wholly owned by the applicant, owned two buildings as 
part of its assets. 
5 As a general rule, IMT is levied on transfers, for value, of the right of ownership, 
or parts of that right, over immovable assets located in the national territory. 
6 In accordance with Article 2(2)(d) of the Código do IMT (IMT Code) (as worded 
in the version in force in 2019), the concept of the transfer of immovable assets 
includes the ‘acquisition of holdings in companies or shares [or interests] in 
general partnerships, limited partnerships or limited companies, where those 
companies or partnerships are the owners of immovable assets and where, by that 
acquisition, by amortisation or by any other means, any shareholder or partner 
comes to hold, at least, 75% of the share capital [or partnership interests] or the 
number of shareholders or partners is reduced to a married couple or a 
cohabiting couple’ (emphasis added). 
7 The applicant maintains that that provision is contrary to EU law and, in 
particular, to Council Directive 2008/7/EC of 12 February 2008 concerning 
indirect taxes on the raising of capital. 
8 This question is crucial to enable the arbitration tribunal to assess the lawfulness 
of the supplementary assessment for IMT contested by the applicant, as there are 
reasonable doubts regarding the interpretation of various articles of Directive 
2008/7/EC in the context of the main proceedings. 
2.2. The applicant’s arguments 
9 The present case concerns the formation of a capital company (the applicant) by 
means of a contribution of capital within the meaning of Article 3(a) of Directive 
2008/7/EC, which should not be subject to any kind of indirect taxation, pursuant 
to Article 5(1)(a) of that directive. 
NOVA IBEROMOLDES 
 
3 
10 The transfer of the limited company shares in ‘Edilásio Carreira da Silva Lda.’, 
which was the form in which the contribution of capital was made and which gave 
rise to the assessment for IMT at issue, is not included in the exception provided 
for in Article 6 of Directive 2008/7/EC, both because ‘limited company shares’ 
are not securities [for the purposes of Article 6(1)(a) of that directive] and because 
IMT does not constitute a ‘transfer duty’ [for the purposes of Article 6(1)(b) of 
that directive]. 
11 Even if it were accepted that the transfer was subject to IMT, the IMT levied 
would, in any event, contravene the single rate principle established by that 
directive, since the rates applied exceed the maximum limit of 1% provided for in 
Article 8(3) of Directive 2008/7/EC. 
2.3. The arguments of the TCA 
12 Not only does Directive 2008/7/EC not prohibit the Member States from taxing 
the transfer of securities, it permits it under Article 6(a). 
13 The IMT Code includes among the transfers on which that tax is to be levied 
certain transactions which, directly or indirectly, imply the transfer of immovable 
assets, in particular the acquisition of holdings in companies, since it is intended, 
precisely, to avoid the possibility of the ownership of such properties being 
acquired, indirectly, through the acquisition of shares or interests in companies or 
partnerships which have such properties among their assets, without the relevant 
tax being paid. Hence, the expression ‘transfer duties’ appearing in Directive 
2008/7/EC may include such situations, which do not involve the simple legal 
transfer of the immovable assets. 
III. REQUEST FOR A PRELIMINARY RULING 
3.1. Subject matter of the request 
14 The present request for a preliminary ruling concerns the interpretation of 
Articles 3(a), 4, 5(1)(a), 6(1)(a) and (b) and 8(3) of Directive 2008/7/EC. 
15 The parties disagree regarding the compatibility with Directive 2008/7/EC of the 
tax levied pursuant to Articles 2(2)(d), 12(4)(19)(a) and 17 of the IMT Code […]. 
3.2. Further considerations 
16 […] 
17 […] 
18 […] 
[competence of the CAAC to request preliminary rulings] 
REQUEST FOR A PRELIMINARY RULING OF 3. 12. 2024 – CASE C-837/24 
 
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19 With regard to the obligation to request a preliminary ruling incumbent on a court 
or tribunal of a Member State against whose decisions there is no judicial remedy 
under national law, in accordance with the Recommendations of the Court of 
Justice of the European Union to national courts and tribunals in relation to the 
initiation of preliminary ruling proceedings, of 8 November 2019 […], that 
obligation falls away where ‘there is already well-established case-law on the 
point or … the correct interpretation of the rule of law in question admits of no 
reasonable doubt’ (paragraph 6). 
20 This arbitration tribunal is not aware of any judgment of the Court of Justice 
providing the interpretation requested. 
21 […] 
22 […] 
IV. RELEVANT FACTS 
23 The applicant is a holding company (sociedade gestora de participações sociais: 
SGPS), incorporated on 28 March 2019 as a public limited company. […] 
24 The applicant was formed with a share capital of EUR 35 512 000.00, divided into 
7 102 400 shares, each with a nominal value of EUR 5 […]. 
25 The applicant’s share capital was fully paid up by means of the following non-
cash contributions (shares and limited company shares), which its sole shareholder 
(Iberomoldes, SGPS S.A.) held in the following companies: 
(i) one million four thousand and sixty-eight (1 004 068) shares in the company 
‘Iber-Oleff-Componentes Técnicos em Plástico S.A.’, […] representing 
99.9998% of its share capital; 
(ii) three hundred and fifty-eight thousand eight hundred and twenty-two 
(358 822) shares in the company ‘Aníbal H. Abrantes – Indústrias de 
Moldes e Plásticos S.A.’, […] representing 96.97892% of its share capital; 
(iii) two limited company shares, with a total value of one million three hundred 
thousand (1 300 000.00) euros, in the company ‘Edilásio Carreira da Silva 
Lda.’, […], representing the entirety of its share capital; 
(iv) one limited company share, with a nominal value of eight hundred and sixty-
seven thousand five hundred (867 500.00) euros, in the company 
‘Iberonorma – Estruturas e Acessórios para Moldes Lda.’, […], representing 
86.75% of its share capital; 
(v) one limited company share, with a nominal value of two hundred and fifty 
thousand (250 000.00) euros, in the company ‘Portumolde – Moldes 
Portugueses, Lda.’, […], representing 50% of its share capital; 
NOVA IBEROMOLDES 
 
5 
(vi) two hundred and ninety-nine thousand nine hundred and twenty (299 920) 
shares in the company ‘Setsa – Sociedade de Engenharia e Transformação, 
S.A.’, […], representing 99,97333% of its share capital. 
[…] 
26 The holding in the company ‘Iberonorma – Estruturas e Acessórios para Moldes 
Lda.’ was […] valued at (EUR 92 000.00) (negative value) […]. 
27 At the date of the taxable event, the company ‘Iberonorma – Estruturas e 
Acessórios para Moldes Lda.’ was the owner [of two urban properties used for 
‘warehousing and industrial activity’]. […] 
[…] 
28 The holding in the company ‘Edilásio Carreira da Silva Lda.’ was […] valued at 
EUR 186 000.00 […]. 
29 [At the] date of the taxable event, the company ‘Edilásio Carreira da Silva Lda.’ 
was the owner of the following properties: 
(i) urban property […] used for ‘residential use’, with a [reference value for tax 
purposes (‘reference value’)] of EUR 140 900.00 (at the date of incorporation of 
the applicant and of the tax inspection); 
(ii) urban property […] used for ‘warehousing and industrial activity’, with a 
reference value of EUR 347 793.15 at the date of incorporation of the applicant 
and a reference value of EUR 358 296.50 at the date of the tax inspection […]. 
30 […] [The] TCA (Direção de Finanças de Leiria) (Leiria Tax Office) carried out a 
tax inspection relating to the 2019 corporation tax liability of the applicant’s sole 
shareholder, in which it concluded, inter alia, that the contribution of assets 
effected for the purposes of the formation of the applicant ‘does not satisfy the 
requirements for the application of the rules on tax neutrality’, for the following 
reasons: 
‘subsequent to [the execution of] the instrument of incorporation of Nova 
Iberomoldes (executed on 28 March 2019), that is, after the asset contribution 
transaction had been carried out, in which, supposedly, [the taxable person] 
transfers the branch of activity in exchange for shares in the beneficiary company, 
assignments of credit were concluded (on 30 June 2019, three months after the 
incorporation of Nova Iberomoldes) relating to additional capital contributions 
made by the taxable person to the companies whose shares it transferred to Nova 
Iberomoldes, in which Nova Iberomoldes is recognised as the debtor and 
undertakes to pay the amounts assigned. Those assets (additional capital 
contributions – equity instruments) are intimately linked to the transferred assets 
(holdings in companies), but did not form part of the supposed transfer of the 
branch of activity, nor were they taken into account for the purposes of the 
REQUEST FOR A PRELIMINARY RULING OF 3. 12. 2024 – CASE C-837/24 
 
6  
consideration in shares in the beneficiary company, since they were not included 
in the asset contribution transaction[;] … under the transaction, one part of part 
of the net assets was transferred (that is, only the share capital, but not all of the 
equity instruments of those entities) – excluding its branch of activity, which was 
retained, as well as the rest of the related activity – without the material, human 
and financial resources used to manage the holdings, which allow it to constitute 
an autonomous economic unit or whole capable of operating by its own means.’ 
[…] 
31 As a result of that inspection procedure relating to 2019 corporation tax, a 
supplementary assessment was made for that tax […]. 
32 That supplementary assessment for corporation tax was partially annulled by a 
decision […] of 5 December 2023, but the TCA still considers that the rules on tax 
neutrality do not apply […]. 
33 […] [The] TCA (Leiria Tax Office) carried out a tax inspection relating to IMT 
for the 2019 financial year and concluded that: 
With regard to the company ‘Iberonorma – Estruturas e Acessórios para Moldes 
Lda.’ 
‘… it has been stated that, “in relation to items ‘463’ to ‘612’, given that the two 
cadastral references are contiguous and there is no physical separation on the 
ground, it is not possible for us to determine precisely to which of the cadastral 
references some of the items relate, although, for others, it has been possible to 
make that determination”. 
In view of the fact that the entity itself was not able to identify the cadastral 
reference for some items of the fixed assets, stating that the references concerned 
are contiguous and that those items could appear under urban cadastral reference 
U-864 or U-1578-A, in the absence of a distribution criterion provided by the 
taxable person and given that this value is compared with the reference value, a 
breakdown of the net book value of those items at 31 March 2019 (totalling 
[EUR] 50 459.21) was prepared, according to the percentage of the reference 
value represented by each cadastral reference in that same period, compared to 
the total reference value of the two properties.’ 
[…] 
With regard to the company ‘Edilásio Carreira Silva Lda.’ 
‘In relation to items “68” to “633”, it is stated that they are included in cadastral 
reference U-4813 and/or cadastral reference U-10239, both located in the district 
of Marinha Grande. In view of the age of the assets (all prior to 2004) and the fact 
that the buildings are contiguous, it is not possible to state precisely whether they 
appear under reference U-4813 or U-10239. 
NOVA IBEROMOLDES 
 
7 
Moreover, it should be noted that, in the first quarter of 2020, the operating 
activities of the company were moved to the installations located at […] Marinha 
Grande (premises 3), and therefore items “742” to “942” relate to improvements 
at those installations, with the exception of item “840”, which is related to 
references U-4813, U-10239 and premises 3. 
Given that the entity itself identified some of the fixed assets as not being included 
under cadastral reference U-10239 or under urban cadastral reference U-4813, 
those items were excluded from the calculation of the net book value at 31 March 
2019 for those two properties (totalling EUR 212 556.17). 
With regard to item “840” of the fixed assets, the entity could not identify the 
relevant cadastral reference, stating that it relates to urban cadastral references 
U-10239 and U-4813 and premises 3. Therefore, due to the absence of any 
criterion provided by the taxable person, the net book value at 31 March 2019 
(EUR 9 700.93) was assigned to the three properties equally and 2/3 of that value 
was calculated on a pro rata basis, that is, EUR 6 467.29 [[(EUR 9 700.93/3) x 2] 
= EUR 6 467.29], according to the reference value that each of the two cadastral 
references had in that same period (in the absence of a distribution criterion 
provided by the taxable person and because this value is compared with the 
reference value). 
Furthermore, given that the entity could not identify the cadastral reference of the 
remaining fixed assets, stating that the references in question are contiguous and 
that those items could appear under urban cadastral reference U-10239 or U-
4813, in the absence of a distribution criterion provided by the taxable person and 
given that this value is compared with the reference value, a breakdown of the net 
book value of those same items at 31 March 2019 (totalling EUR 1 145 947.38) 
was prepared, according to the percentage of the reference value represented by 
each cadastral reference in that same period, compared to the total reference 
value of the two properties.’ 
[…] 
34 The TCA determined the net book value at 31 March 2019 of the following 
properties: 
‘Iberonorma – Estruturas e Acessórios para Moldes Lda.’ 
[(i) urban property used for ‘warehousing and industrial activity’, with a total 
net book value at 31 March 2019 of EUR 350 546.99; 
(ii) urban property used for ‘warehousing and industrial activity’, with a total 
net book value at 31 March 2019 of EUR 119 431.35.] 
[…] 
‘Edilásio Carreira Silva Lda.’ 
REQUEST FOR A PRELIMINARY RULING OF 3. 12. 2024 – CASE C-837/24 
 
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[(i) urban property used for ‘residential use’, with a total net book value at 
31 March 2019 of EUR 332 264.18; 
(ii) urban property used for ‘warehousing and industrial activity’, with a total 
net book value at 31 March 2019 of EUR 820 150.49.] 
[…] 
35 In the final inspection report, the TCA determined the following taxable amounts 
in respect of IMT: 
 
Reference value compared to the balance sheet book value 
1 2 U 3.a 3.b 4 5 
Tax ID Company District 
Cadastral 
reference Fraction 
Current 
reference 
value 
Reference 
value in 
March 
2019 
Balance 
sheet book 
value in 
March 
2019 
Taxable value 
for IMT [rule 
19 of 
Article 12(4)(a)] 
500753199 Edilásio 
Carreira 
Silva Lda. 
101001 
Marinha 
Grande 
4813 
 
10239 
140 900.00 
 
358 296.50 
 140 900.00 
 
347 793.15 
332 264.18 
 
820 150.49 
332 264.18 
 
820 150.49 
500753180 Iberonorma 
Estruturas 
e 
Acessórios 
p/ Moldes, 
Lda. 
100123 – 
União das 
Freguesias 
de Pataias e 
Martingança 
864 
 
 
1578 
 
 
 
A 
165 686.07 
 
 
73 361.02 
160 829.03 
 
 
71 210.46 
350 546.99 
 
 
119 431.35 
350 546.99 
 
 
119 431.35 
Total         
 
[…] 
36 For the purposes of determining the IMT liability, the TCA concluded that an 
amount of EUR 95 356.52 was owed, which was calculated as follows: 
Calculation of the IMT 
1 2 U 6 7 8 
Tax ID Company District 
Cadastral 
reference Fraction 
Percentage 
ownership 
Taxable 
value 
for IMT of 
the 
percentage 
owned 
Rate of 
IMT 
500753199 Edilásio 
Carreira 
101001 
Marinha 
4813 
 
10239 
 100.00% 
 
100.00% 
287 213.00 
45 051.18 
4.1578% 
8.00% 
NOVA IBEROMOLDES 
 
9 
Silva Lda. Grande 820 150.49 6.50% 
500753180 Iberonorma 
Estruturas 
e 
Acessórios 
p/ Moldes, 
Lda. 
100123 – 
União das 
Freguesias 
de Pataias e 
Martingança 
864 
 
 
1578 
 
 
 
A 
86.75% 
 
 
86.75% 
304 099.51 
 
 
103 606.70 
6.50% 
 
 
6.50% 
Total        
 
[…] 
37 With regard to the properties belonging to the company ‘Edilásio Carreira Silva 
Lda.’, the TCA concluded that an amount of EUR 68 855.61 was owed in respect 
of IMT, plus interest amounting to EUR 11 024.45 […]. 
[…] 
38 On 22 September 2023, the applicant filed the request for arbitration which has 
given rise to these proceedings, contesting the amount of IMT relating to the 
properties belonging to the company ‘Edilásio Carreira Silva Lda.’. 
V. RELEVANT PROVISIONS OF EUROPEAN UNION LAW 
39 Articles 3(a), 4, 5(1)(a), 6(1)(a) and (b) and 8(3) of Directive 2008/7/EC. 
VI. RELEVANT PROVISIONS OF PORTUGUESE LAW 
40 The IMT Code was introduced into the Portuguese legal system in 2003 by means 
of Decree-law No 287/2003, of 12 November 2003, although Article 2(2)(d) of 
that code, mentioned above, is by no means innovative. That provision merely 
gives continuity to point 6 of the first paragraph of Article 2 of Lei n.º 41969, de 
24 de novembro de 1958 (Código do Imposto Municipal de Sisa e do Imposto 
sobre as Sucessões e Doações) (Law No 41969 of 24 November 1958 (Code on 
the Municipal Tax on Transfers of Immovable Assets and on the Tax on 
Inheritances and Gifts)): 
‘CHAPTER I 
Scope 
Article 1 Permanent or temporary transfers of assets, whatever the basis on which 
they are made, shall be subject to the tax on transfers of immovable assets and the 
tax on inheritances and gifts. 
REQUEST FOR A PRELIMINARY RULING OF 3. 12. 2024 – CASE C-837/24 
 
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Article 2 The tax on transfers of immovable assets is levied on the transfer of the 
ownership of immovable assets for value, with the exception of consolidated fixed 
assets. 
1. To that end, the transfer of immovable property shall mean: 
[…] 
6. The acquisition of holdings in companies or shares [or interests] in general 
partnerships, limited partnerships or limited companies, as well as amortisation 
or any other situation, where those companies or partnerships are the owners of 
immovable assets and where, as a result of that acquisition or situation, any 
shareholder or partner comes to hold, at least, 75% of the share capital [or 
partnership interests] or the number of shareholders or partners is reduced to 
two, and those two are husband and wife, married according to the rules for joint 
ownership of property, whether acquired before or during the marriage.’ 
41 The wording of the following provisions of the IMT Code is that of the version in 
force at the date of the relevant facts (2019): 
‘Article 2 
Objective and territorial scope 
1- IMT is levied on transfers, for value, of the right of ownership, or parts of that 
right, over immovable assets located in the national territory. 
2- For the purposes of paragraph 1, the concept of the transfer of immovable 
assets also includes: 
[…] 
(d) the acquisition of holdings in companies or shares [or interests] in general 
partnerships, limited partnerships or limited companies, where those companies 
or partnerships are the owners of immovable assets and where, by that 
acquisition, by amortisation or by any other means, any shareholder or partner 
comes to hold, at least, 75% of the share capital [or partnership interests] or the 
number of shareholders or partners is reduced to a married couple or a 
cohabiting couple.’ 
‘Article 12 
Taxable amount 
1- IMT is applied to the value recorded in the instrument or contract or, if it is 
greater, the reference value of the properties for tax purposes. 
[…] 
NOVA IBEROMOLDES 
 
11 
4- However, the provisions of the preceding paragraphs shall be without 
prejudice to the following rules: 
[…] 
19. Where the transfers referred to in Article 2(2)(d) and (e) take place, the tax 
shall be calculated as follows: 
(a) on the basis of the reference value of the properties for tax purposes [stated] 
in relation to the majority shareholding or interest or, where relevant, the total 
value of such assets; in both cases, the balance sheet book value shall be used, if 
that is greater;’ 
‘Article 17 
Rates 
1- IMT is levied at the following rates: 
[…] 
(b) Acquisition of an urban property or an autonomous fraction of an urban 
property exclusively for residential use, not included in the previous point: 
 
Value to which IMT is applied 
(in euros) 
Percentages 
Marginal Mean (*) 
Up to 92 407 1 1 
Greater than 92 407 and up to 
126 403 2 1.268 9 
Greater than 126 403 and up to 
172 348 5 2.263 6 
Greater than 172 348 and up to 
287 213 7 4.157 8 
Greater than 287 213 and up to 
550 836 8 - 
Greater than 550 836 6 (flat rate) 
(*) At the upper limit of the band 
[…] 
(d) Acquisition of other urban properties and other acquisitions for value – 6.5%.’ 
REQUEST FOR A PRELIMINARY RULING OF 3. 12. 2024 – CASE C-837/24 
 
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VII. REQUEST FOR A PRELIMINARY RULING AND QUESTIONS 
REFERRED 
42 In light of the foregoing, the arbitration tribunal decides: 
(a) In accordance with Article 267 TFEU, to refer the following questions to 
the Court of Justice for a preliminary ruling: 
1. Must a tax (such as the IMT at issue in the present case) which is levied on 
transfers, for value, of the right of ownership, or parts of that right, over 
immovable assets, and which equates to the concept of the transfer of 
immovable assets any situation by virtue of which a shareholder or partner 
comes to hold, at least, 75% of the share capital or partnership interests in a 
company or partnership owning immovable assets, be regarded as an 
‘indirect tax’ on the raising of capital, for the purposes of Council Directive 
2008/7/EC of 12 February 2008 [concerning indirect taxes on the raising of 
capital]? 
2. If the first question referred is answered in the affirmative, for the purposes 
of that directive, must a transaction, such as that forming the subject matter 
of the present case, whereby a capital company, within the meaning of 
Article 2 of Council Directive 2008/7/EC of 12 February 2008, is formed to 
carry on the activity of managing holdings in companies and the entirety of 
the share capital is paid up by means of the contribution of holdings that the 
contributing company (which also carries on the activity of managing 
holdings in companies) had in other companies, without any other element 
or resource or even the entirety of the equity instruments being transferred, 
and in which, as consideration, the contributing company receives the 
entirety of the share capital in the beneficiary company, be regarded as a 
contribution of capital (within the meaning of Article 3 of that directive) or 
as a restructuring operation (within the meaning of Article 4 of that 
directive)? 
3. If the first question referred is answered in the affirmative, does 
Article 5(1)(a) or (e) of Council Directive 2008/7/EC of 12 February 2008 
preclude tax being levied on the transaction in question pursuant to 
Article 2(2)(d) of the IMT Code, which equates to the concept of the transfer 
of immovable assets the transfer of shares or interests representing at least 
75% of the share capital or partnership interests in a company or partnership 
owning immovable assets[?] 
4. If the third question referred is answered in the affirmative, for the purposes 
of Article 6(1)(a) of Council Directive 2008/7/EC of 12 February 2008, must 
the ‘limited company shares’ transferred be regarded as ‘securities’? 
5. If the third question referred is answered in the affirmative, for the purposes 
of Article 6(1)(b) or (c) of Council Directive 2008/7/EC of 12 February 
2008, must IMT be regarded as a ‘transfer duty’? 
NOVA IBEROMOLDES 
 
13 
6. If Article 2(2)(d) of the IMT Code is considered compatible with Council 
Directive 2008/7/EC of 12 February 2008, do Articles 8(3) and 11 of that 
directive preclude the rules laid down in Articles 12(4)(19)(a) and 17 of the 
IMT Code, in accordance with which a tax rate of between 1% and 8% is 
applied, according to the taxable amount, which is determined taking into 
account the reference value of the properties for tax purposes or the balance 
sheet book value, if that is greater? 
[…] 
[National procedure] 
CAAD, 3 December 2024 
The arbitrators, 
[Illegible signatures] 
[…]