Portuguese court rules insolvent individual is liable for tax on property sale gains in insolvency proceedings.

The Supreme Administrative Court unanimously ruled that the insolvent individual, not the administrator, is the taxpayer liable for income tax on gains from property sales during insolvency proceedings. The Recurrent argued against this attribution, but the Court affirmed the statutory definition of the passive subject in insolvency contexts. Consequently, the decision clarifies that the insolvent retains tax liability despite the transfer of assets to the administrator.