Qual Justiça Fiscal para os Países em Desenvolvimento em um Mundo Globalizado?

Abstract

Globalization brought a new scenario and different challenges regarding tax justice, fiscal jurisdiction and sovereignty. In this sense, due to this evolution, the relations between the OECD Member-States and the developing countries shall be re-analyzed, mainly the residence and territoriality principles, in light of that new cultural, economic and political context. The aim of this article is to point out how those consequences might impact the ideal of an interstate tax justice and the special role of bilateral agreements in order to reach balance and harmonization of the local tax law with the Tax Treaties.