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This book analyses the treatment of income of individuals under Brazilian double taxation conventions. Each article of the Brazilian tax treaties is analysed in order to identify its characteristics, field of application, limits and criteria applied in the identification of taxpayers. The OECD Model Convention is also considered, since it is mirrored in Brazilian conventions. The analysis reveals the unconstitutional nature of Articles 17 and 19 of the Brazilian treaties as they contradict the constitutional principle of isonomy.
Our intention is to follow both the English and the German paradigms, that is, to work in an accessible language (an English tendency) and to think problems through, like Germans do.
Obra originalmente apresentada como Dissertação de Mestrado ao Departamento de Direito Processual da Faculdade de Direito da Universidade de São Paulo (Brasil)