As Convenções para evitar a Dupla Tributação Brasileiras

Técnicas de Negociação e Análise Estrutural segundo os Modelos OCDE e ONU

Abstract

Firstly, the empirical frameworks of this work are the Treaties to Avoid Double Taxation that are in force between Brazil and non-Latin-American countries. Departing from that, the historical background, negotiation aspects and the praxis of the application of Brazilian Tax Treaties are analyzed. After those analysis, an article by article comparison between the before mentioned treaties and the OECD and the ONU Models is held, highlighting the differences between them. Finally, a summary of the most common peculiarities and negotiation perspectives of them is produced.