Decree-Law 453/99 of 5 November ("DL 453/99") established the legal regime relating to Securitization in Portugal and regulates the incorporation and activity of Securitization funds ("FTC's") Securitization companies ("STC's").

Decree-Law 219/2001 ("DL 219/2001") establishes the tax regime relating to DL 453/99. DL 219/2001 conceptually establishes the (i) tax neutrality treatment of FTC's and STC's and (ii) tax competitive character of the securities to be issued by the FTC's and STC's (the "Securities").

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