Rui Camacho Palma

Rui is head of Tax in the firm’s Lisbon Office, specialising in international tax planning, the tax aspects of public and private M&A, corporate reorganisations, intellectual property, structured and hybrid finance, and tax litigation, as well as providing standalone advice on clients’ key tax requirements. 

Rui has extensive experience in structuring a wide array of inbound and outbound investment projects in Portugal, Angola and Mozambique.

Before joining Linklaters in 2007, Rui spent nine years working for major global consultancies, including heading a team as an international tax manager.

Work highlights

Rui has acted for major clients on the tax aspects of some of the most complex and sophisticated transactions. These include advising:

• Banco Santander Consumer Portugal (BSCP) and Santander Consumer Finance on the set-up of a contractual partnership between BSCP and Banque PSA Finance, the financial arm of PSA Peugeot Citroën group
• Barclays Bank on the sale of its Barclaycard consumer payments business (assets worth £1bn) in Portugal and Spain to WiZink
• AXA on the €191m sale of its Portuguese business to Ageas Insurance International
• Eni on the Rovuma Basin US$40bn project in Mozambique, the largest Liquefied Natural Gas (LNG) project in Africa
• BHP Billiton Group on the Mozal aluminium smelter, within the overall global restructuring in the context of the BHP Billiton Group’s demerger
• Magnum Industrial Partners and other co-investors on the €1bn sale of Iberwind - Desenvolvimentos e Projectos to a vehicle wholly owned by Cheung Kong Infrastructure Holdings and Power Assets Holdings
• Secil, the Portuguese cement company, in its groundbreaking successful tax case before the European Court of Justice where the court ruled that no tax should be levied in Portugal on dividends distributed to a Portuguese parent company by certain non-EU subsidiaries pursuant to Euro-Mediterranean Association Agreements

Rui heads community investment initiatives in the firm’s Lisbon office.  

Rui Has been a member of Amnesty International for more than 25 years and he conducts training programmes for school children on human rights.

Rui lectures at the Lisbon Catholic University and also writes regularly for trade and learned journals on tax matters. His articles include

“The practical protection of taxpayers’ fundamental rights”, IFA Branch Report (Portugal), Basel Congress, 2015

“European Tax Treatment of Additional Tier 1 Capital Instruments”, Tax Notes International, Special Reports, 2014

“Åklagaren v Hans Åkerberg Fransson: Charter(ing) new territory”, British Tax Review, 2013

“X Holding: A Flawed Judgment or yet Another Lesson in Consistency?”, EC Tax Journal, Vol. 12, 2011-2012

“An Overview of the Protection of Taxpayer Rights in Portugal”, European Taxation, 2010, and, in Chinese, Taxation Translation Journal, 2010

Rui studied law at the University of Lisbon Law School and for a master’s in taxation at the Institute of Advanced Legal Studies, University of London.

He speaks Portuguese, Spanish, English, French and German.