Lisbon, July 9, 2025 (Lusa) - A group of 21,500 large debtors is responsible for around 62% of the debt that the Tax and Customs Authority (AT) can no longer recover, according to data from the Ministry of Finance.
According to the report on combating tax and customs fraud and evasion for 2024, recently submitted by the Government to Parliament, at the end of last year, the AT had €9.764 billion in debt classified as uncollectible.
Of this total, around €6.08 billionoriginated from so-called “strategic debtors”.
The AT classifies debtors in this way and monitors them through the Integrated Management System for Strategic Debtors (SIGIDE) whenever one of three circumstances occurs: if the total debt registered with a tax office reaches €500,000; if the total debt in more than one tax office exceeds €250,000; or if the sum of the debt amounts to 80% of the debt portfolio registered with a tax office.
In addition to these three basic criteria, the list also includes companies in insolvency proceedings whenever the AT joins the creditors’ committee and the taxpayer has yet to join SIGIDE.
The AT considers a debt uncollectible whenever it determines that a taxpayer has no assets available for seizure and the tax authorities cannot seize assets from successors, joint or subsidiary liable parties.
Between individual taxpayers and collective entities, the AT had 21,520 debtors classified as strategic at the end of last year.
In total, this core group of debtors had accumulated debts of approximately €16.89 billion, accounting for around 62% of all debt registered by the AT (€27.242 billion).
Of the 16.89 billion euros, a portion remained collectable.
The government report indicates that 42% represented suspended debt (suspension occurs when taxpayers pay in instalments, submit an administrative complaint to the AT or initiate legal action), 36% was classified as defaulted (uncollectible), and 22% was in a processable stage of collection.
At the end of 2024, the AT had 1,542,333 tax enforcement proceedings against strategic debtors, representing around 7% of the 23,443,686 existing nationwide.
In its opinion on the General State Accounts for 2023, the year before that covered by this report, the Court of Auditors points to the volume of uncollectible debts as “an increased risk factor for the sustainability of public finances”.
At that time, several factors had contributed to the increase in uncollectible debt, “such as the financial crises, the Covid-19 pandemic and the recent energy crisis”, to which we added “the impact of the change in case law regarding the lasting effect of the interruption of the statute of limitations, which has led to a very significant increase in the number of cases declared in default and a reduction in the statute of limitations”, the court said in its opinion of 27 September 2024.
Regarding attachments triggered by the AT, the government’s anti-fraud report indicates that the number of cases decreased “slightly” in 2024, contrary to the trend observed in the previous two years.
The total number of attachments decreased from 649,184 in 2023 to 624,932 in 2024, representing a 3.7% decline.
The attachment of income and other assets (excluding wages) remains the most common (383,600 cases, 61% of attachments).
This is followed by the attachment of credits (110,000 cases, 18% of cases) and, in third place, the attachment of wages (86,000 cases, 14% of the total).
In fourth place are attachments of real estate (22,500 cases, 4% of the total) and pensions (12,100 cases, 2%).
Attachments of rents, vehicles, commercial establishments, savings certificates, boats and furniture account for a residual weight.
PCT/ADB // ADB.
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