A regra de revelação obrigatória de planejamentos tributários agressivos e o princípio da transparência tributária

Abstract

This dissertation investigates compatibilities and incompatibilities between mandatory disclosure rules of aggressive tax planning and the principle of tax transparency applied to Brazilian tax law. The research is divided into four chapters. The first chapter deals with international tax transparency. The second chapter studies aggressive tax planning and rules for its mandatory disclosure, based on action 12 of the BEPS Project and international experience. The third chapter studies the principle of tax transparency applied to Brazilian tax law. The fourth chapter seeks to identify compatibilities and incompatibilities between the establishment of mandatory disclosure rules and the principle of transparency applied to Brazilian tax law. The research is based on primary and secondary sources and studies the principle of tax transparency as an empty content principle. The study fits within the context of international tax transparency and Brazil's adhering to the transparency standards set forth in action 12 of the BEPS Project. It is a problem whose implementation depends on further studies. What is presented, in the meantime, are compatibilities and incompatibilities between mandatory disclosure rules and the principle of tax transparency applied to Brazilian tax law.