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Purpose Autonomous taxation of expenses (ATE) is a special and contentious feature of corporate income taxation in Portugal. By taxing of an expanding set of corporate expenses, it has caused many conflicts between the Portuguese tax authority and corporate taxpayers. Many of these conflicts emerged from the legal interpretation of ATE’s clauses, while others derived from frequent, and difficult to apply, legislative changes. The purpose of this paper is to focus on the following research question: does the recent evolution of the rules on ATE show an efficient process of making and interpreting tax law in Portugal? The authors intend to analyze the process of making and changing ATE’s rules, as well as to study how interpretative complexity increases conflicts between tax authorities (TA) and taxpayers. Design/methodology/approach The methodology used is a mix of the legal research method, namely, doctrinal methodology, with an analysis of jurisprudential and arbitration trends in litigation rulings, blended with the case study analysis of ATE in Portugal. Arbitration rulings will have a particular relevance to the analysis. Findings The main conclusion is that, urged by the need of revenues, and sensitive to the TA’ argument of ATE’s loopholes, the government hastened to close them. However, given the procedure adopted, new legal questions aroused, creating additional layers of complexity for companies, courts and tax auditors. Constitutional issues were highlighted by companies based on the prohibition of retroactive application of tax laws. Research limitations/implications The paper has a conceptual nature and its conclusions cannot be automatically extended to other tax controversies or processes of amending tax laws. However, for the legal and accounting professions it offers valuable lessons in law interpretation and political lobbying to change tax laws. Also, in the international tax scene, some countries also introduced ATE, with potential for similar problems. Practical implications Regarding ATE’s streamlining, the process recently observed in Portugal was not, in authors’ view, managed in the best way, leaving a significant number of difficulties to be solved by courts. The change in ATE’s legal framework could have been more carefully managed, avoiding costly and time consuming disputes, in order to minimize compliance costs. Originality/value The paper contributes to the literature because this Portuguese experience, while highlighting the difficulties in making tax law, can be seen as a lesson on how to improve these processes, avoiding time and costs for business, TA and courts. Moreover, arbitration is a way of solving tax disputes that has been gaining ground in Portugal. In this respect, the paper also contributes to a better perception of the tax arbitration scenario in anEuropean Union country. It is also important for the accounting profession, whose members have often to deal with tax topics and the interpretative complexities they originate.

This article discusses the issue of taxation of insolvent companies in Portugal, particularly regarding the Portuguese tax on revenue of legal entities (IRC). For this purpose, first, some considerations on the legal framework of insolvent companies are woven and, second, their tax regime is analyzed. Then, a brief review of the main studies that, in the international context, analyze and debate major issues derived from the tax regime of insolvent companies is conducted, particularly in Brazil, Spain, United States, and Italy. Finally, there are the results of an empirical study conducted in Portugal, in 2013, which evaluates and compares the opinions of insolvency administrators (IA), the tax and customs authority (TA), and court magistrates (CM), in order to contribute to a better solution concerning business taxation under this regime. Respondents (IA, TA, CM) demonstrate objective thinking about the fact they believe it is very important that the Portuguese Code of Insolvency and Business Recovery (CIRE) and the Portuguese Code of Tax on Revenue of Legal Entities (CIRC) are modified, now to make clear whether the settlement of property ownership of an insolvent estate is liable to the IRC, then to assign a chapter specifically devoted to the subject of taxation on insolvency in Portugal. Este artigo discute a problemática da tributação das sociedades insolventes em Portugal, nomeadamente em sede de imposto sobre o rendimento das pessoas coletivas (IRC). Para o efeito, em primeiro lugar, tecem-se algumas considerações sobre o regime jurídico das sociedades insolventes e, em segundo, analisa-se o seu regime fiscal. Seguidamente, procede-se a uma breve revisão dos principais estudos que, no contexto internacional, analisam e debatem os principais problemas criados pelo regime fiscal das sociedades insolventes, em especial no Brasil, na Espanha, nos Estados Unidos e na Itália. Finalmente, apresentam-se os resultados de um estudo empírico, conduzido em Portugal, em 2013, que avalia e confronta as opiniões de administradores da insolvência (AI), da autoridade tributária e aduaneira (AT) e dos magistrados judiciais (MJ), com o objetivo de contribuir para uma melhor solução na tributação de empresas nesse regime. Os entrevistados (AI, AT, MJ) apresentam pensamento objetivo sobre o fato de considerarem muito importante que o Código da Insolvência e da Recuperação de Empresas (CIRE) e o Código do Imposto sobre o Rendimento das Pessoas Coletivas (CIRC) sejam alterados, ora para esclarecer se a liquidação do patrimônio da massa insolvente está sujeito a IRC, ora para atribuir um capítulo especialmente dedicado à matéria da tributação na insolvência em Portugal.

The relevance of the impact of tax complexity on tax noncompliance justifies the study of tax complexity in the scope of several taxpayers, including local authorities. This chapter analyses the case of the value added tax (VAT), a typical example where the misuse of exemptions and no subjections imply the no payment of taxes by citizens. Therefore, this chapter tries to assess, qualitatively and quantitatively, the levels of tax complexity perceived in local authorities' administrations through the amount of binding tax information those organizations request. The results suggest a high degree of perception of tax complexity and uncertainty as well as a lack of transparency associated with the tax framework of the activities of local authorities. It is pointed out that the perceived complexity is essentially legal. Moreover, the findings establish a relation between some more complex legal changes with great tax impact within these entities and the increase of the number of binding tax information requested on their subjects.

This paper describes the RobChair assistive navigation system. The RobChair project was conceived with the aim to assist disabled people in the difficult task of manoeuvring a powered wheelchair. This paper describes the overall hardware and software architecture including the communication system, a friendly graphical user interface which also works as a simulator and introduces a natural human-machine interface. The system's architecture follows a behaviour-based control architecture.