A (in)suficiência do procedimento amigável no contexto das garantias dos contribuintes

  • Ana Carolina Magalhães Braga Andrade (Student)

Student thesis: Master's Thesis


This dissertation's main objective is to determine what changes can be made to the current Mutual Agreement Procedure under the Article 25 of the OECD Model Convention for resolving disputes arising from the application of the Convention, in order to provide more protection for taxpayers. To this end, we will first analyze the current regime, highlighting its disadvantages, and then make an analysis of taxpayer’s guarantees in Portuguese tax law as a source of inspiration. We will also
mention some increased rights for taxpayers when one of the contracting states is Portugal.
Date of Award29 Jan 2024
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorLeonardo João Santos (Supervisor)


  • Mutual agreement procedure
  • International double taxation
  • Taxpayer´s rights
  • OECD model convention


  • Mestrado em Direito

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