DEBRA e a mitigação do debt-equity bias

Abstract

The present dissertation aims at analyzing the adequacy of the debt-equity bias mitigation enshrined in the proposal for a Council Directive (COM(2022) 216 final) laying down rules for a deduction in respect of the increase in equity and for limiting the deductibility of interest for corporate income tax purposes. We will start with a brief background, focused on the so-called debt-equity bias issue. Then, we will critically review the main provisions of the proposal, explaining how the equity deduction is calculated and how the rule limiting the deductibility of interest operates. We will identify some features that, in our view, require further clarification or amendment. We will conclude by presenting the solution that we believe best meets the resolution of the underlying societal challenge.

Date of Award	18 Jul 2023
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	João Félix Pinto Nogueira (Supervisor)