O regime de participation exemption

: análise dos n.ºs 13 e 14 do art. 51º do código do IRC

Abstract

The present work focuses on the critical analysis of the specific anti-abuse rule transposed by the Parent Subsidiary Directive, as set out in Article 51 of the Corporate Income Tax (CIT), including numbers 13 and 14. At the beginning of 2014, our tax system underwent a major renovation in relation to the taxation of businesses. Thus, this paper focuses on analyzing the changes introduced by the CIT reform in Portugal under the participation exemption regime. In order to better understand where Portugal stands in the European context, a comparative study based on legal frameworks were conducted in Portugal, Spain, Dutch, Luxembourg and Malta, aiming to highlight the regimes’ similarities and disparities. Despite all the efforts, the remaining differences between the aforementioned regimes still lead to a low attractiveness and competitiveness in the Portuguese regime.

Date of Award	27 Sept 2017
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Inês Viseu Carvalho de Pinto Leite (Supervisor)