Arbitragem no Direito Tributário Internacional

Abstract

The purpose of the present article is to analyze if arbitration could be adopted in the Brazilian double taxation conventions as a method of resolution of treaty disputes, as well as the mutual agreement procedure. The institute is firstly explored from the point of view of the OECD Model Convention, as a way to verify that both from internal and international law perspectives the arbitration is an effective way to solve disputes in tax matters.