In the international tax law arena, coordination is the key-word of the moment, once there is a strong consensus that a coordinated tax governance can provide more effi cient and egalitarian tax systems for both taxpayers and tax authorities, in which States are objects and players. In this sense, the present article aims at determining the role and position of Brazil as regards international tax governance, mainly in a post-BEPS scenario, offering a bigger picture of the Brazilian policy. However, fi rst, it is essential to establish the concept, object, and players of international tax governance. Once presented the theoretical framework, this study will provide an analysis not only of the Brazilian transfer pricing rules, especially the discussion towards an (un) desirable full convergence with the OECD standards, but also the implementation of BEPS minimum standards (Actions 5, 6, 13 and 14) through modifi cations in the domestic law and the Peer Reviews released by the OECD. At the end, some conclusions will be presented to pave the horizon for future debates.

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