O impacto das recomendações do BEPS no regime dos preços de transferência

Abstract

In an era in which the number and size of economic groups, particularly multinational enterprises, has increased considerably and, because of globalization and the creation of a single market, commercial activities are developed across borders, it is becoming increasingly common for companies to undertake planning manoeuvres on an international scale to reduce taxes. One of the strategies adopted by the taxpayers with the referred aim is the use of transfer pricing. In the first stage, we approached the payment of taxes as a duty, which we later counter with a possible right to tax planning. In this context, we studied transfer pricing as a planning mechanism and identified the tax revenue implications of this practice. Based on this conclusion, we assessed the scope and effectiveness of the initiatives of countries and international organizations to avoid tax erosion and profit shifting practices and evaluated the status quo of the Portuguese regime regarding the issue under analysis.

Date of Award	6 Nov 2017
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Mónica Duque (Supervisor)