This article examines a Portuguese decision on the application of a tax treaty's non-discrimination clause to extend the domestic relief available under domestic law to a person that, according with the wording of such clause, would be excluded from it.In this case, the author believes that the...

The present study was developed based on the IBFD EU Task Force’s submission within the framework of the European Commission 2021 public consultation on the use of shell entities and arrangements for tax purposes. The analysis of the broad ramifications of this central issue within corporate...

Portuguese Abstract: Esta contribuição teve como objetivo rever criticamente as razões apresentadas por organizações internacionais, governos e decisores políticos para justificar as medidas/iniciativas destinadas a enfrentar os desafios fiscais decorrentes da digitalização da...

Tax collection is vital to maintain fiscal sustainability. According to a World Bank report, developing economies average 15% of Gross Domestic Product (GDP) in tax collections which is lower than that in advanced economies i.e. 40%. This inability of the developing economies recognizes weak...

Italian Abstract: In questo scritto si commenta la pronuncia della Corte di giustizia dell’Unione europea (in seguito ‘CGUE’ o la ‘Corte’), prima sezione, del 20 gennaio 2021 relativa al caso Lexel AB (nel prosieguo ‘Lexel’). Questa sentenza è stata emessa senza le conclusioni...

Defined value clauses used to value nonmarketable family limited partnership (FLP) interests create valuation distortions and other public policy issues. This paper describes these abuses and proposes the employment of restrictions similar to those applied to pecuniary formula marital deduction...

The Court’s judgment in Société Générale reinforces the established case law that EU law neither prohibits juridical double taxation as such nor does it put an obligation on the residence Member State to prevent the disadvantages which could arise from the exercise of competence thus...

This chapter focuses on addressing the prospective compatibility of the proposed Pillar Two rules with EU primary law and, in particular, the fundamental freedoms. In this respect, the authors observed that, as the Pillar Two package is a composite one, a distinction would need to be made...