The Brazilian Perspective on International Tax Law

Abstract

Abstract This chapter explores the perspective of Brazil regarding international tax law. It cites how Brazil is a prime example of how the growth of countries might result in the adoption of tax positions, which are more in line with the OECD Model Tax Convention. Despite engaging in the signature of double tax conventions, Brazil took advantage of every situation to increase its source taxing rights, going beyond the OECD and UN Model Tax Conventions. The chapter considers the influences of the UN Model Tax Convention, BEPS actions and the Multilateral Instrument (MLI) on the Brazilian domestic tax rules. It then acknowledges Brazil as a trendsetter for favouring taxation based on real economic criteria over formal considerations.