As a result of the signature by the Portuguese Republic, on June 7 2017, of the Multilateral Convention to implement tax treaty related measures to prevent base erosion and profit shifting (“MLI”), on April 4, the Portuguese Government submitted to the Assembly of the Portuguese Republic the Resolution Proposal no. 90/XIII, aimed at the approval of the MLI and the formulation of the respective declarations and reserves.
Pursuant to the application of BEPS (Base Erosion and Profit Shifting) recommendations project adopted in 2015 to the tax conventions entered into between the signatory States, MLI envisages the adoption of measures aimed at preventing the abusive use of the aforementioned conventions, and thus the fight against international evasion and fraud, namely the artificial transfer of profits to locations with low or zero levels of taxation and erosion of the tax base.
In addition, MLI’s objective is to improve the resolution of disputes in this area between the parties, through the establishment of a mandatory and binding arbitration procedure.
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