International Taxation

Recommended Prerequisites

Accounting

Portuguese Taxation

Teaching Methods

The teaching methodologies are:

 

1- Presentation of conceptual aspects related to the treatment of the unit´s topics

2- Analysis of the regulatory framework (e.g., DTA, CIT, EU Directives) at the international level

3- Discussionabout topics for which interpretive doubts are mostly raised

4- Resolution of practical cases and jurisprudential analysis of international tax disputes

Learning Outcomes

The course unit objetives/outcomes are:

a)Highlight tax topics that corporate managers operating in an international economic  environment should take into consideration

b)Analyse the instruments (Tax treaties, EU Directives, etc.) that such corporations can use in the tax management of operations

c)Prepare stduents to work in a international tax environment, with a special focus on tax planning and anti avoidance measures

d)Highlight the importance of transfer pricing and group taxation

e) Identify and analyze research topics in I.Tax

Work Placement(s)

No

Syllabus

1. International double taxation of income and ways to avoid it. The EU vs USA case.

EU directives on corporate income taxation.

  2. The OECD model and the Double Taxation Conventions: main norms and practical application

3. Participation exemption regimes

4. Profit shifting and the OECD BEPS project: its impact on the CIRC

5. Transfer pricing: OECD Guidelines and Portuguese legal norms

6. Taxation of groups of companies in PT and in the European Union

7. Brief notions of tax harmonization: recent progress in the EU

8. Research: international taxation issues

Head Lecturer(s)

António Manuel Ferreira Martins

Assessment Methods

Assessment
Exam: 100.0%

Bibliography

Martins, António and Taborda, Daniel (2017), Taxes and management: an introduction, e-book, Coimbra, Almedina, pp. 110.

http://www.almedina.net/catalog/ebook_info.php?ebooks_id=97897240720506

 Michael Lang, Pasquale Pistone, Josef Schuch, Claus Staringer (2020) Introduction to European Tax Law on Direct Taxation, Sixth edition, Spiramus ed.

 OEC (2022) Transfer pricing Guildines; Paris, OECD Publications.

 Angharad Mille and Lynne, Oats (2020) Principles of International Taxation, London, Bloomsbury.