A reforma da tributação internacional da renda e seus reflexos sobre a política tributária internacional brasileira

Abstract

Globalization and the digital economy have changed the way in which multinational enterprises (MNE´s) operate. New business models, beyond increasing tax evasion´s and avoidance´s risk, escape the current rules of the international tax systems, whose foundations were developed almost a century ago and no longer suit to the current socioeconomic structures. Based on the premise that the sharing of global space leads to a scenario in which national tax policy can no longer be designed in isolated way, especially in view of the State's inability to guarantee the compliance of its tax rules on transnational businesses, this paper describes the distortions observed in the international tax regimes and presents a descriptive and explanatory analysis of the reformist agenda conducted by the OECD in the course of the BEPS project. Emphasizing the allocating of taxing right´s rules, the research examines the new rules applicable to digital economic activities and their impacts on consumer states, especially Brazil. It is argued that, although Brazilian international tax policy has been developed independently of global standards, alignment with the BEPS project may be desirable depending on the political agreements reached.