Selective BEPS in the New Portugal - U.K. Tax Treaty

Tax treaties have evolved from mere instruments for the elimination of double taxation to become active tax policy instruments.

The new treaty between Portugal and the United Kingdom is a clear illustration of this shift: it strengthens anti-abuse measures and expands the powers of source taxation, while taking a cautious approach to dispute resolution.

Today, compliance with formal requirements is no longer enough; the challenge is to withstand an increasingly demanding substantive analysis.

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