Análise sobre a incidência da cláusula ppt no planejamento tributário internacional e a norma de combate à evasão fiscal brasileira

Abstract

This article aims to study the OECD Model Convention, limited to Article 29 created through Action 6 of the BEPS Project and the PPT clause. Starting from the PPT clause, the Direct Action of Unconstitutionality No. 2446/DF is also analyzed, and with this the insertion of a general anti-evasion rule, a GAAR in the Brazilian legal system, as well as the possible consequences of a domestic GAAR tied to the Agreement to avoid bitaxation and its impacts on the PPT Clause. The themes mentioned will be studied from theoretical research, using bibliographic, documentary analysis, and through inductive method