This contribution aimed at critically revising the reasons put forward by international organisations, governments, and policy-makers to justify the measures/initiatives aiming at addressing tax challenges arising from the digitalisation of the economy.A careful review of the measures seems to...

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...

[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”,...

English Abstract: The new coronavirus has reinforced problems that states have been facing in recent years with regard to the tax challenges arising from the digitalization of the economy, especially with regard to large technology multinationals that earn extraordinary profits across the globe,...

Taxes designed to counter unsustainable behaviours that lead to environmental destruction are usually styled as surtaxes on purchase prices. It makes more sense to locate the source of the profits derived from such behaviours and tax them in order to internalize the environmental costs that are...

An initiative is needed to break the logjam in the international negotiations to reform taxation of multinational enterprises (MNEs). The primary agreed goal of the project on Base Erosion and Profit Shifting (BEPS) was to better align MNEs’ taxable profits with the location of real economic...