Os Elementos de Conexão no Direito Tributário Internacional

Abstract

To establish a comparative analysis of the most important connection elements in the face of the respective Brazilian legislation (constitutional or ordinary). Previously to such analysis, to face at least three matters: i) the nature of juridical norms originally derived from International Tax Law sources when of the enthronement of such norms at Brazilian legislation; ii) the relation of International Tax Law in the ambit of Brazilian tax legislation and iii) the issues of interpretation and qualification conflicts.