The Social Contribution on Net Profits and the Substantive Scope of Brazilian Tax Treaties – Treaty Override or Legislative Interpretation?

This article considers aspects of the social contribution on net profits (contribuição social sobre o lucro liquido, CSLL) in relation to the substantive scope of tax treaties concluded by Brazil and, inter alia, whether the enactment of a domestic law dealing with the application of the CSLL involves a treaty override or simply a legislative interpretation.