Heleno Taveira Torres

htHELENO TAVEIRA TORRES is Professor of Financial Law Holder of the Law School of the University of São Paulo (USP). Professor and Associate Professor of Tax Law at the same institution since 2003.Doctor (PUCSP), Master (UFPE) and Specialist (Università di Roma – La Sapienza) in Tax Law. It was worldwide vice president of the International Fiscal Association – IFA, based in Amsterdam – Netherlands, January 2008 to December 2013. Vice-President of the Brazilian Association of Financial Law – ABDF. Member of the Executive Council of the Latin American Institute of Derecho Tributario – ILADT, and other important associations in Brazil and abroad, as ABRADT, IAB, IASP.

It is counselor of the Supreme Council for Legal Affairs and Legislative (Conjur), Director and Member of the Arbitration Panel of the Federation of São Paulo State Industries – FIESP, Director and Member of the Arbitration Panel of the Federation of São Paulo State Trade – FECOMERCIO.

He is the author of books: Direito Constitucional Financeiro – Teoria da Constituição Financeira. SP: RT – Revista dos Tribunais (Thomson Reuters), 2014; Direito constitucional tributário e segurança jurídica. 2. ed. São Paulo: RT, 2012 (1. ed. 2011); Fundo soberano do Brasil e finanças públicas. Belo Horizonte: Editora Fórum, 2012. Co-authored with Felipe da Cunha Rodrigues; Derecho tributario y derecho privado: autonomía privada, elusión y simulación. Buenos Aires: Marcial Pons, 2008; Direito tributário e direito privado: autonomia privada, simulação e elusão tributária. São Paulo: RT, 2003; Direito tributário das telecomunicações e satélites – Estudos e pareceres. São Paulo: Quartier Latin, 2006; Pluritributação internacional sobre as rendas de empresas. 2. ed. São Paulo: RT, 2001 (1. ed. 1997); Direito tributário internacional. São Paulo: RT, 2000, and several coordinated books and articles published in Brazil and abroad.

Member of the Editorial Board of the Journal World Tax Journal, the International Bureau of Fiscal Documentation – IBFD (Amsterdam). Member of the Editorial Rivista Diritto Internazionale Tributaria and Practice Committee, issued by CEDAM. Member of the Editorial Committee of the Rivista di Diritto Tributario Internazionale, published by the Dipartimento di Theory dello Stato, the Facoltà di Scienze Politiche, R Università di Roma – “La Sapienza”, and other foreign and domestic issues.



Alessandra Okuma

AOALESSANDRA OKUMA It is PhD in Tax Law (2009), the Pontifical Catholic University of São Paulo – PUC / SP, with thesis “The Anti-elusive Domestic and International Standards in International Tax Law”. Master of Laws PUC / SP (2005), with thesis “The Principle of Non-Discrimination in the Brazilian International Law”. Specialist in Tax Law from the Pontifical University of São Paulo PUC / SP – COGEAE (2001). He graduated in Law from PUC / SP (1997). It was a member of renowned São Paulo law firms.

She is a professor at the National Institute of Postgraduate – INPG, foreign trade tax discipline. Author of several articles published in specialized books and magazines such as: “Principle of Non-Discrimination and the Taxation of Non-Resident Income in Brazil”, in International Tax Law, vol I; “The Taxation of subsidiaries and affiliated companies”, in International Tax Law Applied v.II; “Do Pis and Cofins on import”, in Controversial Issues in Tax Matters; “Practical application of the principle of non-discrimination – the taxation of dividends remitted by a resident company to partner-shareholder not resident” in Jurisprudence Repertory IOB 3/2005; “Taxation of Dividends Remitted to Non-Residents Comments on the Superior Court decision in Special Appeal No. 602725 / PR.” Interests in Public, 2005; “Non-discrimination Issues in Brazil- Spain Double Taxation Treaty”, in Diritto Internazionale and Pratica Tributaria. n. 01; “Taxation of Dividends Remitted to Non-Residents. Comments on the decision of the Superior Court in Special Appeal No. 602725 / PR “, in International Tax Law Applied, Vol. III; “Comments of the Court Superior Court in Special Appeal n 426945 / PR”, in International Taxation and Trade; “Termination of Brazil – Germany Double Taxation Treaty”, in Diritto Internazionale n Tributaria and Practice. 03; “Procedures for Resolving International Tax Disputes and Brazilian Law”. Diritto and Pratica Tributaria Internazionale v. 2; “The Conventions to Avoid Double Taxation and tax avoidance and dispute settlement means” in International Tax Law Applied, Vol. IV; Interpretation of Treaties to Avoid Double Taxation – TDTs and its extension to the Social Contribution on Net Income in Journal of Tax Studies, vol. 67; The international circumvent tax and international tax transparency regime. Journal of International Tax Law, vol. 12.