The CFE Tax Advisers Europe welcomes the judgment of the Court as it provides further clarification on the legal protection of the information holders afforded by Article 47 of the Charter of Fundamental Rights of the European Union in cases of cross-border exchange of information. Article 47 of...

Abuse is one of the core issues in EU direct tax matters. Much has been written over the past years. The discussion on the interpretation and application of the different elements of the anti-abuse clauses appears to be settling. However, an equally fascinating discussion appears to be emerging:...

This article provides an overview of the main tax changes introduced by the Portuguese State Budget for 2012.The Portuguese State Budget for 2012 (the budget) is, most likely, the most ruthless piece of legislation approved in the roughly 40 years of Portugal's democracy. Nevertheless, the...

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...

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...

This article examines the compatibility of the OECD's proposed rules on GloBE (pillar II) with EU law, covering both primary law and secondary law. In addition, it discusses the amendments required by the implementation of this initiative within the internal market. In what concerns...