O Montante B do Pilar 1 e a mobilidade dos trabalhadores

  • Beatriz Constança Matos Pinto Pereira (Student)

Student thesis: Master's Thesis

Abstract

The aim of this dissertation is to analyze whether there is any relationship between the OECD Pillar 1 Amount B and worker mobility. In particular, we set out to study the impact that this worker mobility can have on the scope of application of Amount B. To do this, we carry out an analysis based on practical examples, from which we question whether or not the fulfillment of the criteria for the scope of application of Amount B is affected by worker mobility. Having reached this central point of our study, we conclude that the application of Amount B to a tested party can be affected by the mobility of its employees, especially since the verification of the criteria of its scope requires, as a prior step, the preparation of a functional analysis. Finally, we study whether and how it is possible to isolate this impact, and how to deal with cases where it is not possible to isolate it.
Date of Award17 Jul 2024
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorFilipe Cerqueira Alves (Supervisor)

Keywords

  • Amount B
  • Pillar 1
  • Employee mobility
  • Transfer pricing
  • Functional analysis
  • Functions
  • Risks
  • Assets
  • BEPS
  • Qualitative and quantitative indicators
  • Work from home and work from anywhere
  • Groups of multinational companies
  • Internationalization
  • Tax efficiency
  • Principle of private autonomy
  • Principle of tax equity

Designation

  • Mestrado em Direito

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