This article provides a comprehensive review of the Portuguese tax treaty network and of its deviations from the OECD and the UN model Convention. It is undisputed that the OECD Model is the archetype that inspires Portuguese tax treaty policy and shapes most of the solutions contained in...

This book chapter provides a comprehensive overview of the tax framework applicable to non-for-profit charities in Portugal. It was drafted as the Portuguese national report for the EATLP congress, that took place in Rotterdam

[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...

[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...

States have complex and often conflicted attitudes toward migration and citizenship. These attitudes are not always directly expressed by lawmakers, but they may be reflected quite explicitly in tax regimes: for the world's most prosperous individuals and their families, multiple states extend a...

This paper discusses the current trial of McKesson Canada Corporation v. The Queen in the Tax Court of Canada and the related-party debt factoring arrangement and transfer pricing issues between McKesson Canada Corporation and McKesson International Holdings III S.A. R.L, a company resident in...

Every nation has an interest in sharing the gains they help create by participating in globalization. If governments fail to claim an adequate share of these gains, they will be forced to look ever more intensely to personal taxes on their own already-burdened citizens. Yet because of the...

This article deals with the decision taken by the Court of Justice of the European Union in European Commission v. United Kingdom ("Final Losses") (Case C-172/13), published on on the 3 February 2015. This case is in some ways a follow-up to the ECJ's decision in Marks & Spencer (Case C-446/03)...

This article deals with the decision taken by the Grand Chamber of the Court of Justice of the European Union in World Duty Free Group (formerly Autogrill España); Banco Santander and Santusa Holding (Joined Cases C-20/15 P and C-21/15 P), on 21 December 2016, following decisions of the General...

This article examines the decision of the Grand Chamber of the Court of Justice of the European Union (ECJ) in Berlioz Investment Fund SA (Case C-682/15) delivered on 16 May 2017, following the Opinion of Advocate General Wathelet of 10 January 2017.The case concerned the levying of tax...