Tributação internacional dos dividendos

Abstract

The first rules on the taxation of dividends, dating from the nineteenth century, at which time, intensified international economic exchanges and consequently there was an increase in the phenomenon of double taxation. The growing need to combat the aforementioned phenomenon, meant that the League of Nations, create a model package of agreements on double taxation which is termed, models of Geneva, 1928. Regarding the taxation of dividends, the Geneva package provided tax rules exclusive of the States (the source or residence). Next, models were developed in Mexico and London, with solutions similar to the package of Geneva for the taxation of dividends. Shortly after the demise of the League of Nations, was created the United Nations, where questions of international double taxation began to be discussed. Simultaneously, they created the European Organization for Economic Cooperation and Development (OEEC), which issued recommendations regarding double taxation on February 25, 1955, and subsequently submitted a draft bilateral agreement to avoid double taxation, to be adopted by member countries. Upon termination of the OEEC, created the OECD and was already in the midst of this, which was published in 1963, the first version of the OECD MC and their comments. A model, which brings major innovations in the taxation of dividends, therefore, adopts a solution for the distribution of taxing powers between the State of source and residence. Finally, in 1980, the United Nations presents a model which is based on the principles and structure of the OECD model, aiming to meet the concerns of the developing countries.

Date of Award	2012
Original language	Portuguese
Awarding Institution	Universidade Católica Portuguesa
Supervisor	Rui Duarte Morais (Supervisor)