The IBFD Task Force on the Digital Economy prepared an earlier version of this document for the purpose of commenting on the policy, technical and administration issues raised by each of the Three Proposals [hereinafter: the Proposals] contained in Section 2 of the Public Consultation Document...

This study aims to provide feedback to the OECD on its Public Consultation, launched on 8 November 2019, on the specific matters of the Global Anti-Base Erosion (GloBE) Proposal, also known as Pillar Two of the BEPS 2.0 Project, as included in the Public Consultation Document (The "Public...

The article deals with the interesting issue of the tax treaty qualification problems arising in hybrid financial instruments and structures. The need to fit the great diversity of instruments and legal, economic and accounting trends attached to them into the closed range of treaty income...

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...

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...