: do processo da sua transposição ao respetivo impacto no sistema fiscal português

  • Maria Inês Martins Moreira (Student)

Student thesis: Master's Thesis


This dissertation focuses on the importance of the most recent amendment to the Directive of Administrative Cooperation. In particular, a thorough analysis of the changes that the Council Directive (EU) 2018/822, of May 25 2018, brings regards to the previous one and what are the effects and implications of its transposition in the portuguese tax system. Throughout this writing, some of the reasons that gave rise to the aforementioned Directive will also be addressed. Since it appears as a means to combat tax evasion and avoidance, it is important to pay attention to the context of aggressive tax planning, with express mention to BEPS Action 12 and also reflect on the objective of transparency that informs all means of combating tax evasion and avoidance. The scope of the Portuguese law in relation to the Directive will be analyzed, which is higher than that intended by the latter, imposing a paradigm shift in the professional secrecy and extending the rules of the Directive to internal operations. A reflection will be made on the benefits and/or damages that can be expected from the national legislator's option, and the requirements that will now be imposed on all taxpayers and on the Tax Administration will also be reviewed. The dissertation will continue with a personal forecast about the result of the new impositions resulting from the same transposition and how the new paradigm may be qualified in terms of the new required procedures. After a brief reference to how the same Directive has been transposed in other Member States, the respective conclusions will be drawn.
Date of Award19 Jul 2021
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorMaria Odete Oliveira (Supervisor)


  • European Union
  • Tax Exchange of information
  • BEPS Action 12
  • Tax transparency
  • Tax evasion
  • Tax avoidance
  • Prefessional secrecy


  • Mestrado em Direito

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