The purpose of this dissertation is to analyse the integration of articles 7 and 8 of the anti-avoidance directive in Portuguese tax law. The goal of this study is to ascertain how Portuguese law should adopt the mechanisms that are hierarchically imposed by European Union law concerning the specific anti-abuse rule on controlled foreign companies. We will have a comprehensive approach, considering the CFC rule, and its negative and positive integration. Finally, we will compare the current Portuguese legislation and the provisions contained in the anti-avoidance directive on CFC. It emerges from this analysis that the anti-avoidance directive is a (timid) evolution and that Portuguese tax law will have to go through several changes in order to make the antiabuse clause in question compatible with European Union law.
Date of Award | 7 Jul 2017 |
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Original language | Portuguese |
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Awarding Institution | - Universidade Católica Portuguesa
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Supervisor | João Félix Pinto Nogueira (Supervisor) |
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- Controlled foreign companies
- Holding companies
- Controlled company / subsidiary
- Multinational enterprise
- Tax policy
- Tax legislation
- Tax havens
A nova regra SEC da diretiva anti-elisão e o seu impacto no ordenamento tributário português
Martins, N. M. V. D. C. P. (Student). 7 Jul 2017
Student thesis: Master's Thesis