O segundo pilar de tributação da OCDE

: a subject to tax rule: análise crítica e aplicação no ordenamento jurídico nacional

Abstract

In order to tackle the new obstacles that the digital economy has raised, the OECD has developed a set of measures denominated the Second Pillar of Taxation. Within this set of rules is the Subject to Tax Rule, which aims to protect the tax economy of Developing Countries. To this end, this rule aims to target illicit transfers of income that take place within the large business groups. However, despite its well-intentioned objectives, the Subject to Tax Rule has a highly limited scope that may compromise its ability to achieve the proposed objectives. This dissertation aims to study the Subject to Tax Rule and the respective criticisms. At the same time, potential changes are presented in order to increase its impact on Developing Countries. In addition, an analysis of the impacts that the Subject to Tax Rule will have on the National Legal System is carried out.

Date of Award	17 Jul 2024
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Filipe Cerqueira Alves (Supervisor)