A tributação das operações financeiras das empresas

: a dedutibilidade dos gastos de financiamento ao abrigo do artigo 23.º do CIRC

Abstract

The present dissertation is focused on the matter, broadly discussed in case law, and, increasingly, in doctrine, of the deductibility of financial expenditure under article 23 of CIRC. Specifically, and facing the divergencies, which, sometimes, are seen in court about the theme, it will be sought to discern the one that's been the understanding of the doctrine and the case law about the verification of business purpose of interest, confronting and analyzing, as much as possible, the several arguments that substantiate the many positions on this topic. This being said, in the first part, it will be examined the general clause of spending deductibility, as well as the interpretation done about it. On a second moment, attending the particular controversy assumed, it will be dedicated special attention to the interest deductibility in the scope of gratuitous intragroup financial operations, as well as business restructuring operations in the form of reverse merger.

Date of Award	3 Feb 2021
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Luís Bandeira (Supervisor)