Joao,
Years ago I had an issue to get the deposit back from Touring Club Switzerland. I contacted directly FIA. The person in charge was called Deborah Smith. She was extremely helpful and kind. Her email was dsmith (at) fia dot com
If she's still there (I hope she is, I insist, she was just GREAT), she may help you, since they tell the Associations how to apply the rules of CdP, as they clarified the case to TCS.
You may try with RACE Spain, I do not know the calculations they make, but the deposit is SO LOW even for Iran. Check with them, I'm sure you may manage well with Spanish language if you are Portuguese. If you need help, I may help you (I'm Spanish).
Good luck and happy travels,
Esteban
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