Um Regime para a Tributação Internacional

Perspectivas para o Brasil

Abstract

The notion of an international tax regime consists in accepting that there are some core rules in the international tax law which achieved a level of stability able to include them as part of the international law. Nevertheless, supporters of this notion normally consider core rules those which were built under the universality principle paradigm. This article has a different perspective, inspired in Klaus Vogel’s ideas, which argue that the taxation of cross-border situations could be better justified under the territoriality principle, both by an economic efficiency and a justice point of view. Therefore, it presents the rules that should be supported by developing countries, like Brazil, in eventual future discussions to construct the regime.