Rocha, Paulo Victor Vieira daAssad, Emily Silva2023-11-232024-09-062023-03-032023-11-232023-03-03https://ri.uea.edu.br/handle/riuea/2679This 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 methodAcesso AbertoTributação Internacionalinternational taxationOCDEOECDBEPSBEPSCláusula PPTPTT clauseRegras Gerais AntiabusoGeneral Anti-abuse LawADI 2446DAU 2446Trabalho de Conclusão de CursoDireito