A tributação do mercado digital
: o segundo pilar de tributação da OCDE/G20

  • Guilherme Laranjeira Lima (Student)

Student thesis: Master's Thesis


With globalization, free movement and the elimination of barriers, the growing use of mobile assets and the increasingly intensive use of digital economies due to technological advances, modern states face major challenges when it comes to taxing this digital market. For this reason, the OECD together with the G20 have agreed on a set of measures that aim to prevent base erosion and profit shifting in international taxation, following the BEPS report, Action 1 - which aims to address the challenges raised by the digital economy. The measures adopted by the OECD/G20 are divided into two pillars, and within the Second Pillar four rules have been adopted - the IIR, the UTPR, the SOR and the STTR - being the "strong point" of this Pillar the so-called GloBE Rules – Global antibase erosion Rules – which are composed of the IIR and the UTPR. This master's dissertation aims to explore and is based on the study of the Second Pillar and the rules that are covered by it. Additionally, a critical appraisal of this Second Pillar will be made.
Date of Award19 May 2022
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorJoão Sérgio Ribeiro (Supervisor)


  • OCDE
  • G20
  • GloBE
  • Pillar Two
  • BEPS
  • Taxation
  • Digital economy
  • IIR
  • SOR
  • UTPR
  • STTR
  • Multinational corporations


  • Mestrado em Direito

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