1. The role of BRICS in the forming of a New Legal Order
10th Session
European-Asian Law Congress
Ekaterinburg, 9-10 June 2016
BRICS Law Institute, Russian Association of Legal Experts
IBFD, Ural State Law University
Expert Group for Legal Support of Inter-Governmental Partnership and Integration in the Sphere of Economy, Finance, Taxation and Customs
The role of BRICS in the forming of a New Legal Order
Topic 1. International Tax Treaty Law in BRICS Countries: Prospects for Harmonization
BRAZIL by

2. Harmonization or Brazil: Mutually Exclusive Policies?
What is the National Interest?
Effective Sovereignty: defining the role of FDI
Beyond the Capital-Importer x Capital-Exporter dilemma
Is moving up the global value chain a national priority?
Brazil: Past, Present International Tax Policy
The source-country conundrum: Multilateral x Bilateral x Unilateral Policy
Limited treaty network, broader source-country taxing rights
More than high withholding taxation (12.5%-15%): treaty override through interpretation
Topic 1. International Tax Treaty Law in BRICS Countries: Prospects for Harmonization BRAZIL

3. Harmonization or Brazil: Mutually Exclusive Policies?
Tax Treaty Network: Selected Countries
Treaty w/Brazil
No Treaty w/ Brazil
Source: EY/CNI (2015)
Topic 1. International Tax Treaty Law in BRICS Countries: Prospects for Harmonization BRAZIL

4. Brazil: anti-BEPS or anti-FDI?
Topic 1. International Tax Treaty Law in BRICS Countries: Prospects for Harmonization BRAZIL

5. International Tax Treaty Law in BRICS Countries: Brazil
INSTITUTE FOR AUSTRIAN AND INTERNATIONAL TAX LAW
Welthandelsplatz 1, 1020 Vienna, Austria
Romero J.S. Tavares, Esq., LL.B., M.B.A.
Lecturer, Researcher (DIBT/PhD)