Tributação dos rendimentos gerados pela participação em OIC nacional e estrangeiro

: análise comparativa na ótica do participante pessoa singular residente em território português

Abstract

This dissertation consists of a comparative analysis of the tax treatment of income obtained by natural persons resident in portuguese territory, depending on whether they invest in portuguese or non-portuguese CIUs. Specifically, we intend to determine the differences in Portuguese legislation for the taxation of income derived from equivalent operations, depending on whether the investment is made in a portuguese or non-portuguese CIU. As we will try to demonstrate, the national regime in force, whether by law or regulation, seems to paradoxically benefit investment in non-portuguese CIUs, as far as certain income generating operations are concerned. The investment in a non-portuguese CIU may give rise to a situation of juridical double taxation in the sphere of the investor. To this extent, we will seek to assess how the division of international tax jurisdiction between the portuguese state and the source state takes place, in order to understand in what circumstances and under what terms the income obtained by the investor will be subject to the portuguese tax regime.

Date of Award	14 Oct 2021
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Luís Bandeira (Supervisor)