(R)Evolução do imposto sobre as sociedades no espaço europeu

• Autor(a) principal: Luís, Beatriz Simões Marques
• Data de Publicação: 2019
• Tipo de documento: Dissertação
• Idioma: por
• Título da fonte: Repositório Científico de Acesso Aberto de Portugal (Repositórios Cientìficos)
• Texto Completo: http://hdl.handle.net/10362/89171
• topic: Matéria coletável comum; Matéria coletável comum consolidada; Imposto sobre Sociedades; Sistema Financeiro; Common Corporate Tax Base; Common Corporate Consolidated ax Base; Corporation Tax; Financial Sector; Direito

The establishment of an internal market is one of the central elements of the European integration process. Therefore, one of the goals of the European Union since the beginning is to create an area without internal borders that allow prosperity and social economic cohesion, as defined in the Treaty of Rome. Globalization has, however, exposed the first problems related to the free movement of capital and tax competition. To set the path for a common action at European level in the tax area, several technical works may be highlighted, in particular, the Proposal for a Council Directive on a Common Corporate Tax Base (CCCTB) and the Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB), which will be analyzed hereinafter. Initially discussed in 2001, following an analytical study of company taxation in the European Union prepared by the European Commission, and subsequently studied and debated by the CCCTB working group in 2004 onwards, it was presented in 2011 under the designation of Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB), presenting itself as an ambitious and innovative project. However, the challenges faced could not be overcome at the time. After succeeding some of these difficulties, the European Commission announced in the Commission's Action Plan for Fair and Effective Taxation (2015) that it would re-launch this proposal as a comprehensive solution towards a reform of the corporate income tax in the EU. In this regard, the scope of the initial proposal was divided into two legislative documents: Proposal for a Council Directive on a Common Corporate Tax Base (CCCTB) and a Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB). Nonetheless, a fair and efficient taxation of profits, serving the political project of building the common market, can only be achieved through the implementation of a tax system that is both harmonious and that covers the specificities of all economic sectors. In light of the above, in this dissertation we propose to analyze the interventions that have been made in the scope of the new presented proposals, as well as to analyze in greater detail its possible adjustment to the Financial System. Key-words: Common Corporate Tax Base; Common Corporate Consolidated ax Base; Corporation Tax; Financial Sector.