Real estate-rich share transfers: how CJEU’s Nova Iberomoldes ruling impacts Portuguese RETT

On June 4 2026, the Court of Justice of the European Union (CJEU) delivered a significant ruling in Nova Iberomoldes – SGPS, S.A. v Autoridade Tributária e Aduaneira (Case C-837/24), holding that the Portuguese real estate transfer tax (RETT), when applied to certain share-for-share exchanges, is incompatible with Council Directive 2008/7/EC on indirect taxes on the raising of capital (the Capital Raising Directive). The decision has immediate consequences for corporate reorganisations in Portugal and raises important questions for comparable regimes elsewhere in the EU.

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