Economia digital
: o pilar um e as novas regras do conceito de estabelecimento estável

  • Maria André Ramos Leite (Student)

Student thesis: Master's Thesis


The concept of the traditional economy is currently in bankruptcy. Truly, the concepts of physicality, borders and rigidity have been overcome in the context of the digital economy and e-commerce by dematerialization, delocalization and flexibility. This time, and although the advantages of digital are recognized, namely for governments, it is certain that tax systems have been highly harmed by the actions of multinational companies and taxpayers that evade taxation, eroding tax revenues. Indeed, adapting tax systems to the new economic reality has been one of the major concerns on the global political agenda. It is precisely in this context of contrast between economic reality and legal regulation that the OECD issued, within the scope of the BEPS Project, a Declaration on a two-pillar solution in order to face the fiscal challenges arising from the digitization of the economy, the Two Pillar Report. Due to the relevance of the issue and the topicality of the subject, this research work intends to discern the current system of taxation of large companies through the concept of Permanent Establishment; point out its weaknesses; to take note of the most recent efforts by the OECD and the EU to adapt tax legislation and flag those that have been advanced as problems concerning the applicability of the measures recommended by the OECD, as a final consideration.
Date of Award19 May 2022
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorJoão Sérgio Ribeiro (Supervisor)


  • BEPS
  • OECD
  • Stable establishment
  • Digital economy
  • Statement on a two–pillar solution


  • Mestrado em Direito

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