A dupla tributação de dividendos nos grupos de sociedades

Abstract

The present thesis addresses, essentially, an analysis of the Parent-Subsidiary Directive which deals with the tax treatment of dividends between companies in different Member States.7 In the first chapters remarks are going to be made about some contributions for Parent Subsidiary Directive publication. In the first place, we will approach the creation and developments of groups of companies, which influenced the direct taxation law evolution in European Union. Thereafter, we will analyse the direct taxation harmonization in the european context, which is very important for common market aim, despite the lack of consensus among the Member States in this matter. Then we will make a brief explanation about the important role of Court of Justice of the European Union in direct taxation. Its judgements were able to harmonize interpretations and definitions made by Member States that collided with fundamental freedoms. Finally, we will make an explanatory study and, at certain moments, critical study about the Parent-Subsidiary Directive. The aim is to scrutinize in detail the scope of its application and to make brief considerations about the application of the regime’s benefits and about the general anti-avoidance rule of the Directive.

Date of Award	20 Jan 2021
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Tomás Tavares (Supervisor)