The Legality of Brazil's Dual Method of Implementing Selected GloBE Model Rules through Dynamic Reference

This article examines whether Brazil’s dynamic reference to OECD GloBE documents — used to maintain the CSLL Surcharge as a QDMTT — comports with the principle of legality. Although dynamic reference reflects modern soft-law tax governance, its constitutional limits, especially regarding executive delegation in updating secondary legislation, pose potential challenges for Brazil’s implementation model.