The base is the difference, and it is the larger one
The IMT Code provides that, in an exchange, the taxable base is the declared difference in value where that exceeds the difference between the two rateable values. There are therefore two differences to work out, and the larger of them applies.
This matters more in Portugal than it might elsewhere. The VPT, the rateable value held on each property's caderneta predial, is frequently out of step with market value, and by no consistent margin. Where the two properties were last assessed at different times, the gap between their rateable values can exceed the gap the parties agreed on, and it is then the rateable gap that the tax is charged on. Both cadernetas are worth having in front of you before values are settled.
The tax is due from the party receiving the more valuable property. The other pays no IMT at all, even though they too are acquiring a home in the transaction.
