n.1 (2016)

2016 – Edição Especial: princípios fiscais internacionais nos BRICS e países da OCDE

Carta do Editor

Introdução

General Report

Tax Protectionism and Tax Discrimination: Cartography of Multilateral and Bilateral Trade and Investment Agreements

The Internet: Achilles Heel of the Current International Taxation Regime?

Subsidiarity of Tax Treaties in Relation to Domestic Law

Tax Avoidance in Emerging Countries: is a GAAR a Suitable Measure?

Using the Vienna Convention on the Laws of Treaties for Interpreting Tax Treaties

Prevalence of International Treaties in the Brazilian Tax Law

The OECD Intangibles Project and the Concept of “Intangible Related Return”

The Effectiveness of International Trade Agreements for Restricting Tax Protectionism in Brazil

Tax Treaty Interpretation by Supreme Courts: Case Study of CFC Rules

Taxpayers´Protection and International Fiscal Cooperation. Notes

Tax Incentives : III- Advised Tax Policy or Growth Catalysts?

What Should We Talk About When Talking About Tax Incentives for FDI?

Arm´s Lenght Principle and the Issue of Thin Capitalization

World Trade Organisation: BRICS and Direct Taxation

Transfer Pricing: Arm´s Lenght Principle Versus Worldwide Unitary Taxation; Correlative and Secondary Adjustments, and Domestic Legislation under Brazilian Methodology