Corporate Taxation
Objectives
The main aim of this course is to enable the
students to know the tax background related to the most relevant aspects on a
corporate restructuring, on mergers and acquisitions and/or, generically, on
investments in Portuguese companies and/or groups of companies. Main areas of
knowledge to cover and skills to acquire include Corporate Income Tax, Stamp
Tax, Withholding taxes, VAT and anti-abuse rules.
General characterization
Code
14513
Credits
1.5
Responsible teacher
Margarida Ramos Pereira
Hours
Weekly - Available soon
Total - Available soon
Teaching language
Portuguese | English
Prerequisites
Available soon
Bibliography
Portuguese
Constitution / Constituição da República Portuguesa
Corporate
Income Tax Code / Código do IRC
VAT
Code / Código do IVA
Stamp
Tax Code / Código do Imposto do Selo
Tax
authorities web site – e.g. Circulares, Pedido de Informação Vinculativa
Américo
Brás Carlos, João Ribeiro Durão, Maria Emília Pimenta and Irene Antunes Abreu,
“Guia dos Impostos em Portugal”, 2020, Quid Juris
Américo
Brás Carlos, “Impostos – Teoria Geral”, 2016, Almedina
Teaching method
This is an applied course and thus relies extensively on class
discussion of case studies. To contribute to the acquisition of these skills
the following learning methodologies will be used: expositional, participative
and active self-study. Pre-reads and class participation will be an important
component of learning and grading.
Evaluation method
The assessment of this CU is done together with
the block of CUs of the same area of knowledge. This assessment has 3 moments,
which together define the final grade of the CU:
•Individual exam with a weighting of 50% of the
total mark
•Group work with a weighting of 35% of the total
grade value
•Individual reflection-action exercise carried
out at the end of the curricular unit, with a weighting of 15% of the total
grade value. The set of individual action-reflection exercises is a journaling
activity, which will constitute, at the end, a learning portfolio capable of
synthesising the contributions of the Executive Master for that student.
Subject matter
The course will be structured around the
following topics.
• Corporate Income tax
General deductible rules
Tax Unity (groups’ taxation)
Net financial expenses deductibility
Tax losses carryforward mechanism
Transfer pricing rules
Taxation on capital gains (in disinvestment)
Tax neutral regime on mergers and acquisitions
• Withholding taxes on dividends, services,
royalties and interest
• Stamp tax on financings
On principal and/or interest
Available exemptions and its requirements
• VAT
Generic rules
Deductibility on transactions costs
• Other aspects
Limitations on dividend distributions
Anti-abuse rules