A landmark decision by the Portuguese Supreme Administrative Court, published on 9 July 2025, confirms once again that when national tax rules are found to breach European Union law—such as the principle of free movement of capital—investors are not only entitled to full tax refunds, but also to compensatory interest, calculated at an annual rate of 4%.
What makes this ruling especially relevant is the clarification it brings regarding when interest starts to accrue: from the moment the administrative claim is explicitly or implicitly denied—not from the date of a final court ruling. This interpretation aligns with EU law and reinforces the principle of effective restitution for non-resident taxpayers.
At Globe Refund, we have already capitalized on similar legal development—our latest result includes a refund of over €500,000 in just one year on behalf of one of our client, including interest. Our approach goes far beyond standard procedures, combining legal expertise, proactive follow-up with tax authorities, and intelligent claim structuring. Our process is fast, targeted, and uniquely efficient, making it possible to reclaim more—and faster—than traditional providers.
One of Globe's core advantages is our ability to reclaim WHT going back up to 4 years, thanks to our expertise in both ordinary and extraordinary administrative procedures under Portuguese law. Most firms only explore the 2-year standard path, missing out on significant refund opportunities.
This court decision reinforces the urgency for investment funds to review their portfolios for dividend WHT exposure in Portugal, particularly Luxembourg UCITS and other EU-based vehicles.
If you’ve received dividends from Portuguese companies in the past four years, you may be eligible for:
Whether you've already filed or are just starting to explore opportunities, Globe Refund offers a battle-tested strategy that maximizes your outcome, minimizes delays, and ensures compliance with EU law.
Portugal offers two different windows for filing WHT reclaims:
Even if the 2-year window has closed, Globe Refund can still help by leveraging the 4-year route—no need to refile, no claim lost. In fact, we're already managing several high-value claims under the extended timeline.
For cross-border investors, this Portuguese ruling sets a precedent that could influence WHT practices across Europe. But more importantly, it keeps the door open for significant refunds—with interest—for those who act quickly and strategically.
Globe Refund stands ready to support fund managers and family offices seeking to recover undue taxation on dividends. With a proven track record, legal precision, and a results-driven approach, we're not just helping clients reclaim tax—we're helping them protect performance.
To assess your eligibility and initiate your WHT recovery in Portugal (and beyond), contact Globe Refund’s legal and recovery team today.
Our work focuses on providing outsourced withholding tax recovery services to safeguard your investments from over-taxation and save your time from burdensome processes.
