O estabelecimento estável como instrumento anti elisão
: que reconfiguração face aos desafios da economia digital?

  • José Duarte Ribeiro da Costa e Sousa (Student)

Student thesis: Master's Thesis


In this dissertation, we will explain to what extent the Permanent Establishment, as a key criterion for assessing the presence of an enterprise or a group of enterprises in the territory of another State, has become inadequate within the context of the Digital Economy, as well as the consequences that result for those States. Faced with this problem, as well as the consequent outbreak of unilateral measures adopted by several States, the OECD - within the scope of the BEPS Action Plan -, and the European Commission have been presenting solutions towards the reconfiguration of the PE institute and the fair taxation of digital business models. Resorting to the specialized doctrine, our work will involve the analysis of these proposals from the point of view of their viability, their advantages and disadvantages, taking into account the specific characteristics of these business models.
Date of Award20 Oct 2020
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorRui Duarte Morais (Supervisor)


  • Digital economy
  • Permanent establishment
  • Significant digital presence
  • Withholding tax
  • Equalization levy


  • Mestrado em Direito

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