The reality of the world of professional sport, particularly with regard to football and the diversity of income earned by players, raises difficulties with regard to granting the right to tax to a particular state when the income is earned by a resident of a contracting State but with an arguable in another contracting State. The lack of doctrinal and national legislative clarification regarding the classification of the various types of income earned by professional sportsmen within the meaning of Articles 15 and 17 of the CMOCDE, and the consequent discretion as to where it should be taxed, sometimes leads to an excessive appeal to the national jurisdiction of income that should be taxed in another state. Our dissertation aims to carry out an extensive analysis of selected income streams and bring them within the scope of the respective article, thus offering a theoretical solution to the issue of their international double taxation. We have come to the conclusion that this exercise should be relatively effective, since the existence of an apparent right to tax does not mean that exercising this right is the most appropriate solution, due to the various practical problems that would arise.
Date of Award | 17 Jul 2024 |
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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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- Double taxation
- Residence state
- Source state
- OECD
- Income from employment
- Income from a sportsperson
- Sports employment contract
- Sports performance
- Professional football
A tributação internacional dos jogadores de futebol profissional: onde tributar à luz dos artigos 15º e 17º da CM OCDE
Subtil, P. S. A. S. D. (Student). 17 Jul 2024
Student thesis: Master's Thesis