O Princípio do não Retrocesso como Nova Perspectiva à Denúncia de Acordos de Bitributação

Abstract

Notwithstanding the usual position among scholars, according to which International Law would not forbid double taxation, interesting arguments seem to derive from the enforcement of the ability to pay principle within the international scenario. This article, by putting taxation into a human rights’ perspective, investigates whether the non regression principle may be argued as to question the revocation of a tax treaty.