The Concept of Permanent Establishment in Brazilian Law and the Perspective with the Action 7 of the OECD/G20 BEPS Project

Abstract

The objective of this article is to analyze the concept of Permanent Establishment in face of new international paradigms, modified after the OECD/G20 BEPS Project. The idea is to demonstrate how the concept of Permanent Establishment has been developed in Brazil, elucidating the legal framework and also investigating how this concept has been considered in Brazilian administrative and judicial courts. After understanding the new international paradigms, the intention is to discover how Brazil is planning to deal with the situations introduced and solved by the OECD via Action 7.