On March 1, 2024, Circular Letter No. 20267 was issued with the aim of clarifying doubts regarding the exceptional reimbursement regime for retirement savings plans (PPR), education savings plans (PPE) and retirement-education savings (PPR/E), set forth in article 6 of Law no. 19/2022.
In short, and considering the modifications to which Law No. 19/2022 has been subject, the Tax Authority issued the following understanding regarding the temporal scope of reimbursements that may be subject to this legal framework:
| Lex | Scope | Temporal Scope |
| Law 19/2022 | Reimbursement of PPR, PPE and of PPR/E up to the monthly limit of IAS[1] | Reimbursements until 30.09.2022 |
| Law 24-D/2022 | Partial or total reimbursement of PPR, de PPE e de PPR/E for payment of instalments of credit contracts guaranteed by mortgage on property intended for the participant's own and permanent home, as well as instalments of credit for the construction or improvement of properties for own and permanent housing, and transfers to housing cooperatives for permanent own housing solutions, being exempt from the obligation of non-mobilization for at least five years without penalty | Reimbursements until 31.12.2022 |
| Law 24/2023 | Partial or total reimbursement of PPR, de PPE e de PPR/E for payment of instalments of credit contracts guaranteed by mortgage on property intended for the participant's own and permanent home, as well as instalments of credit for the construction or improvement of properties for own and permanent housing, and transfers to housing cooperatives for permanent own housing solutions, being exempt from the obligation of non-mobilization for at least five years without penalty up to the annual limit of 12 IAS | Reimbursements until 27.06.2023 |
[1] IAS (Social Support Index) is the reference for social benefits (€443,20 in 2022 and €480,43 in 2023).
Circular Letter No. 20267 can be consulted here.
