O regime da participation exemption previsto no CIRC

: conformidade entre a exclusão dos países da portaria “paraísos fiscais” e o Direito da União Europeia

Abstract

Along with globalization came a lot of positive aspects, nevertheless a broader interaction between the tax systems allowed situations of ilicit international tax planning, with the main goal of transfering the activities to other countries or regions with a lower or none taxation, decreasing the tax amount in the state of residence. A lot of tax payers resorted to “tax havens” or similar resources and, due to this, States and international organizations are putting a lot of effort in the necessity of decrease the harmful tax competetion, particularly through the enhance of antiabuse mecanisms in their tax legislations. The purpose of this dissertation is to verify the compatibility between one of these measures, which is provided for in participation exemption Regime, analysing if the usage of a “black list system” creates a restriction to the freedom of capital movements.

Date of Award	14 Oct 2021
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Rui Duarte Morais (Supervisor)