According to a study promoted by CIDEFF, a study centre of the Faculty of Law of the University of Lisbon – FDUL, "The most frequent matters for their recourse to justice are 'the basis of calculation' of taxes, the 'unconstitutionality of rules' and 'debt statute of limitations'".

"The study also found that when issues between taxpayers and the AT leave the courts and are resolved through arbitration, decisions are much faster -- 90% of cases are resolved in less than a year", and "the decisions in favour of the State drop drastically", with the tax authorities winning only 23% of arbitration proceedings.

Ana Paula Dourado, professor at the Faculty of Law, and director of the Research Center for European, Economic and Tax Law -- CIDEEFF, who coordinated the study, said that the "purpose of this research is to compare the efficiency and the adequacy of tax justice with tax arbitration in Portugal".

Excessive delays

"The main problem is not access to tax courts, but their excessive delays, which have a profoundly negative impact on the trust citizens have in institutions," she said.

"In a rule of law, a good justice system - that is efficient and fair - must be swift and treat citizens equally", stated Ana Paula Dourado, adding that "it must aim to solve their problems and, in the case of taxes and fiscal justice, the system must attract national and foreign investment" and be "efficient and fair with all types and business dimensions", in addition to "ensuring the collection of public revenue that arises from compliance with the law and the Constitution".