A property developer, nine SPVs, six lenders, no balance sheet

What was wrong

He came in with one sentence: “Move me to Dubai, as a fiscal move.” He wanted to move to Dubai for tax, this year.

He had been building in Lisbon and the Algarve for more than twenty years, successfully by any outside measure. He was also permanently in dispute with the Autoridade Tributária: IVA on construction in one company, IMT on an acquisition in another, IRC assessments across several, and his own IRS on top.

Each project sat in its own SPV. Nine of them. Six banks had lent against them, each with its own maturities and covenants. Three accountants kept the books, none for all of them. Nobody held one list of what was owed, to whom, or when.

At his own estimate he had tens of millions in property. He could not say what he was worth. Property rich, cash poor, he was always selling the next unit to fund the previous project or the loan coming due. He knew buildings better than anyone I have met, and knew his financial literacy was limited. So he was afraid: every letter from the tax office felt like a mistake he had made outside his trade without knowing it.

Dubai was the presenting symptom. It was the wrong question.

What it cost

I rebuilt five years from statements, loan contracts, deeds and tax notices. The loss came to several million.

Price given away: most of it. Five sales were rushed to meet a loan maturity or fund the next site. Each closed about 8% below the comparable asking price his own agent had recommended.

Late tax: the rest, hundreds of thousands. Juros de mora, fines and avoidable IMT and IVA errors across the SPVs. Tax paid late to the Portuguese State accrues interest at the official rate, 7.221% a year in 2026. One IRC and IVA liability settled fourteen months late cost about 8.4% of its value in interest before any fine.

That is the number I defend. Every euro traces to a document; none of it is a market call. It is what disorder costs when nobody owns the calendar.

The move would not have touched the property tax. Under the Portugal–UAE convention, gains from property situated in Portugal may be taxed in Portugal, wherever the owner lives.

Once every entity, loan and tax claim was on one page, his net equity came to roughly half his gross estimate. His own guess, asked the same week, had been “maybe a little, maybe nothing”.

What the fix looked like

Not a new country. A full revamp of the portfolio and the operating set-up around it.

• One balance sheet. All nine SPVs consolidated monthly into one consolidated balance sheet: property at conservative value, debt by lender, accrued and disputed tax.
• One lender ladder. Every facility and maturity on one timeline, eighteen months forward. Refinancing starts nine months out, not three weeks.
• One entity map. Nine SPVs on one page: ownership, directors, banks, open tax matters.
• One filings calendar. Every IVA, IRC, IMT and IRS deadline, owned by one person.
• One accountant of record. Three firms became one, with one chart of accounts.
• One sales rule. No sale below a written floor without a 48-hour review against comparables.
• One liquidity buffer. Enough cash held at group level that no loan maturity can force a sale.

The residence question went to licensed tax advisors in both countries, as part of his cross-border wealth planning, with the new balance sheet in front of them. PWA coordinated them and built the operating layer they worked from. PWA does not manage money, hold mandates, take commissions or give regulated investment, tax or legal advice. The same pattern after a company exit is in consolidated reporting across multiple banks.

Within weeks the anxiety eased; the letters had dates and owners. A year later he told me: “For the first time in my life I feel rich. Until now I didn’t know.”

Should a property developer move to Dubai for tax?

A property developer should not move to Dubai for tax as a fix for disorder. Under the Portugal–UAE double tax convention, capital gains on property situated in Portugal may be taxed in Portugal whatever the owner’s residence: moving the owner does not move the buildings. Residence is a life decision, made with tax planning from licensed advisors in both countries.

A written second opinion would have caught the rest from documents he already had: the loan maturities forcing the sales, the late-tax interest running across nine companies, and the net equity he had never seen.

Request a written second opinion

Sources

• IGCP, Aviso n.º 18/2026/2, Diário da República, 2.ª série, 2 January 2026: late-payment interest on debts to the State, 7.221% from 1 January 2026. Aviso PDF · Vida Económica. Accessed 3 October 2026.
• Portugal–UAE double tax convention, signed 17 January 2011, approved by Resolução da Assembleia da República n.º 47/2012, Article 13(1): gains from immovable property situated in the other State may be taxed in that State. Text on Portal das Finanças. Accessed 3 October 2026.

Pedro Souto is the founder of PWA — Private Wealth Advisory. He works with UHNW founders, families, and single-family offices to build independent advisory structures around complex wealth — consolidating reporting, challenging advisors, and creating clarity across institutions, assets, and decisions.