Os défices normativos do regime europeu de Public Country-By-Country Reporting

  • Manuel Pedro Vale Campos Loureiro (Student)

Student thesis: Master's Thesis


The present dissertation critically examines the normative shortcomings of Directive (EU) 2021/2101 of the European Parliament and of the Council of 24 November 2021 amending Directive 2013/34/EU as regards the public disclosure of income tax information by certain undertakings and branches. The EU, through this “Public Country-By-Country Reporting”, sets new transparency rules seeking to raise greater public scrutiny on the tax planning practices carried out by certain undertakings and branches with activity in the EU. Starting with the presentation of the content and rationale of the Directive, we will critically analyse its regime. Next, we will identify the different normative shortcomings of this Directive, namely in what concerns compliance with the legal certainty principle, to the obstacles to the harmonization, and to an effective implementation of its ratio legis. After identifying these problems, we will propose solutions that could be adopted by the European or domestic legislator (the latter, at the implementation stage).
Date of Award27 Apr 2022
Original languagePortuguese
Awarding Institution
  • Universidade Católica Portuguesa
SupervisorJoão Félix Pinto Nogueira (Supervisor)


  • Tax planning
  • European Union
  • International tax transparency
  • Public Country-by-Country Reporting
  • Legal certainty
  • European legal harmonization


  • Mestrado em Direito

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