As novas regras de abrangência do estabelecimento estável
: BEPS, economia digital e intangíveis (art. 5.º do CIRC)

  • Francisco Mota de Carvalho (Student)

Student thesis: Master's Thesis


This dissertation is about the inappropriate rules of the permanent establishment principle, and the tests described in OCDE Model Convention, regarding the new challenges created by the new businesses being developed by non-residents. The emergence of the Digital Economy has led to the outdating of the current rules about permanent establishment, resulting in a mission to achieve a new concept that can cover the new digitized business models. It is also important to list the various proposals presented about changing the concept of permanent establishment, in order to configure a new model that allows the taxation of companies in jurisdictions where they have no physical presence. It is also understood that intangible assets are a crucial element in the new business models that dominate the Digital Economy. In this dissertation, we will introduce the concept of intangible assets, and its special importance for highly digitalized businesses. Having said that, it will be important to look at all these issues, investigating the work already done and the position of the various affected so that we can draw the final conclusions.
Date of Award27 Jan 2021
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorJoão Sérgio Ribeiro (Supervisor)


  • Digital economy
  • Permanent establishment
  • International taxation
  • International division of taxation law
  • Virtual permanent establishment
  • Physical presence
  • Intangible assets
  • Hard-to-value intangible assets


  • Mestrado em Direito

Cite this