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Fair Value and Corporate Taxation: Out through the Door, Back through the Window?

datacite.subject.fosCiências Sociais::Direito
datacite.subject.fosCiências Sociais::Economia e Gestão
datacite.subject.sdg08:Trabalho Digno e Crescimento Económico
datacite.subject.sdg10:Reduzir as Desigualdades
datacite.subject.sdg12:Produção e Consumo Sustentáveis
dc.contributor.authorMartins, António
dc.contributor.authorSá, Cristina
dc.contributor.authorTaborda, Daniel
dc.date.accessioned2026-10-16T11:49:08Z
dc.date.available2026-10-16T11:49:08Z
dc.date.issued2022-06-23
dc.description.abstractThe progressive harmonization of corporate financial information, based on the International Financial Reporting Standards, has moved fair value accounting (FVA) to the forefront of a debate that straddles accounting and corporate tax. Given the subjectivism that FVA may exhibit, especially when mark to market is not available and mark to model is used as in level 3 FVA, tax legislators have strongly restricted its impact on the corporate tax base. This paper argues that while the Portuguese corporate tax legislators explicitly followed this worldwide trend of restricting the tax impact of fair value to certain circumstances when market prices are observable (level 1 FVA), the corporate tax code has, nonetheless, several important avenues through which FVA influences taxable income determination. The main purpose of this paper is to present and discuss some important ways through which FVA may influence taxable income determination in Portugal, such as goodwill, impairment charges, transfer pricing, capital gains and exit taxation. Thus, the question emerges: is FVA returning through the window to impact the corporate tax base? Considering the global trends in public finance, and the need for present and future tax revenues, we believe this is an important topic to be addressed.eng
dc.description.sponsorshipWe are grateful to the editor and the anonymous reviewers for their valuable comments and suggestions.
dc.identifier.citationMartins, A., Sá, C. & Taborda, D. (2023). Fair Value and Corporate Taxation: Out through the Door, Back through the Window?. Accounting, Economics, and Law: A Convivium, 13(4), 479-499. https://doi.org/10.1515/ael-2021-0046.
dc.identifier.doi10.1515/ael-2021-0046
dc.identifier.eissn2152-2820
dc.identifier.urihttp://hdl.handle.net/10400.8/17077
dc.language.isoeng
dc.peerreviewedyes
dc.publisherWalter de Gruyter
dc.relation.hasversionhttps://www.degruyterbrill.com/document/doi/10.1515/ael-2021-0046/html
dc.relation.ispartofAccounting, Economics, and Law: A Convivium
dc.rights.urihttp://creativecommons.org/licenses/by/4.0/
dc.subjectfair-value accounting
dc.subjectPortuguese corporate taxation
dc.subjectfair value hierarchy
dc.subjectsubjectivism in financial information
dc.titleFair Value and Corporate Taxation: Out through the Door, Back through the Window?eng
dc.typejournal article
dspace.entity.typePublication
oaire.citation.endPage499
oaire.citation.issue4
oaire.citation.startPage479
oaire.citation.titleAccounting, Economics and Law: A Convivium
oaire.citation.volume13
oaire.versionhttp://purl.org/coar/version/c_970fb48d4fbd8a85
person.familyNameSá
person.givenNameCristina
person.identifier.ciencia-idB91F-128A-F372
person.identifier.orcid0000-0001-7066-6121
relation.isAuthorOfPublicationa9302a26-59fb-4541-a1fe-f735d51d7c6c
relation.isAuthorOfPublication.latestForDiscoverya9302a26-59fb-4541-a1fe-f735d51d7c6c

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The progressive harmonization of corporate financial information, based on the International Financial Reporting Standards, has moved fair value accounting (FVA) to the forefront of a debate that straddles accounting and corporate tax. Given the subjectivism that FVA may exhibit, especially when mark to market is not available and mark to model is used as in level 3 FVA, tax legislators have strongly restricted its impact on the corporate tax base. This paper argues that while the Portuguese corporate tax legislators explicitly followed this worldwide trend of restricting the tax impact of fair value to certain circumstances when market prices are observable (level 1 FVA), the corporate tax code has, nonetheless, several important avenues through which FVA influences taxable income determination. The main purpose of this paper is to present and discuss some important ways through which FVA may influence taxable income determination in Portugal, such as goodwill, impairment charges, transfer pricing, capital gains and exit taxation. Thus, the question emerges: is FVA returning through the window to impact the corporate tax base? Considering the global trends in public finance, and the need for present and future tax revenues, we believe this is an important topic to be addressed.
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