Key team member:  

Manuela Simões, General Counsel and Company Secretary

Marta Sommer Ribeiro, Head of Corporate and Finance Law and Fleet

Carolina Mouraz, Head of Litigation and Legal Compliance Director

Mafalda Portocarrero, Head of Commercial Agreements

Anabela Lopes, Head of Data Protection and Data Protection Officer

André Teives, Head of Regulatory and Industry Affairs

Team size: 18

Jurisdictions your role covers: Our team works with Portuguese law but also supervises qualified external work provided in the 32 countries where TAP operates, including engaging local legal counsel and overseeing the matters.

What are the most significant cases or transactions that your legal team has recently been involved in?

Our legal team has advised in high-impact and complex transactions, revealing the scale of TAP’s business and multidisciplinary legal expertise within the department. One of the standout matters was our active involvement in the issuance of US$400mn High Yield bonds in 2024 and US$200mn High Yield bonds in 2025. These transactions required close coordination with external counsel, investors, regulators, and financial institutions, and our team was instrumental in ensuring regulatory compliance, negotiating key terms, and managing risk throughout the process. We also had a leading role in the legal structuring and implementation of TAP’s Restructuring Plan, as approved by the European Commission, which included advising on the reorganization of TAP’s Group and the sale of subsidiaries.

Additionally, our team continues to oversee several critical financing and leasing operations involving TAP’s aircraft fleet. These transactions are multi-jurisdictional and involve technically sophisticated structures, such as Balthazar-backed tax leases and JOLCO tax leases. Also, as these are operationally vital, our legal team is involved in the daily contract management of the fleet and its maintenance, conducting negotiations with lessors, financiers, manufacturers, suppliers and insurers while safeguarding the company’s interests, long-term strategic goals and ensuring compliance with international trade and regulatory requirements.

One of the ongoing matters is the preparation for the privatization of TAP. Our legal team is going to be highly involved in the vendor’s due diligence workstream in anticipation of the government-led sale process.

This includes coordinating the collection and organization of documentation across multiple legal domains — corporate, finance, labour, tax, competition, regulatory, litigation, among others —as well as managing the creation of a structured data room and Q&A and closely accompanying the process together with the external vendor’s and buyer’s legal advisors. In parallel, we are ensuring that the entire process remains aligned with Portuguese privatization legislation, EU state-aid commitments, etc.

Our team members act not merely as gatekeepers but as pragmatic problem solvers. Balancing rigorous risk management, aviation is a highly regulated market, with commercial agility. The scale of these matters showcases the versatility and depth of our in-house practice, as well as our ability to deliver critical projects under demanding timelines.

What factors influence your team’s decision to use external legal services versus handling matters in-house, and what criteria are used to evaluate their performance?

Our legal team retains as much strategic and commercially sensitive work in-house as possible, engaging external counsel only where they can provide distinct added value.

We turn to external legal services in three main scenarios. First, when a matter requires highly specialised expertise or jurisdictional reach that falls outside our internal capabilities. For example, in the recent bond issuance involving a Rule 144A tranche, we mandated firms with recognised experience in US securities law.

Secondly, we engage external support for capacity and timing reasons. During “surge” periods, we may supplement our team to meet tight deadlines without compromising quality. When managing such projects internally, we often rely on a retainer agreement with a top-tier law firm to provide immediate, high-quality backup when required.

Lastly, we outsource certain recurring legal matters, such as passenger claims and night curfew administrative offences. These cases are frequent and require a consistent, streamlined approach. We have established retainer arrangements with specialised law firms to handle these matters efficiently. This ensures procedural timelines are met, representation is thorough, and the legal strategy remains coherent across similar cases. This model has proven more cost-effective than managing the volume entirely in-house, while allowing our internal legal team to concentrate on strategic priorities and more complex legal challenges.

What are some of the biggest legal or regulatory challenges currently facing your industry, and how is your team preparing to address them?

As a state-owned airline, TAP faces not only the regulatory challenges common to all carriers, such as aviation safety, consumer protection, sustainability, sanctions and compliance with international air transport regulations, but also additional matters relating to the oversight applicable to the public sector, which significantly impact our operations.

Moreover, our legal team always works with full awareness of the public and political scrutiny inherent to a state-owned company. TAP operates in a highly visible environment where legal decisions and commercial strategies are frequently subject to external commentary and political oversight. This requires our team to balance strict legal compliance with reputational risk management, transparency and accountability under intense media and public attention.