Tratados internacionais em matéria tributária: uma análise a partir dos casos COPESUL e VOLVO

Abstract

The present work aims to study in a pedagogical manner international treaties in tax matters, with the goal of discussing the solution to the antinomy between international treaties on taxation and domestic legislation, based on the COPESUL and VOLVO cases. To this end, we will initially examine some concepts of tax law that will be pertinent to the full development of the work. Next, we will study international treaties, discussing at the international level the theories that address the antinomy between international treaties and domestic law. Moving forward, we will study international treaties in tax matters, relating the problem of antinomy with Article 98 of the National Tax Code (CTN). Finally, we will explore the COPESUL and VOLVO cases and discuss them in order to find solutions, at the national level, for the conflict between international treaties in tax matters and domestic law.