This article argues that notwithstanding the formal invitation made to the OECD by the G20 to propose solutions to the problem of base erosion and profit shifting (BEPS), some countries, for reasons of their own, may prefer to act unilaterally. Brazil is used as a case study as a result of its intense tax policymaking activity in the past twenty years, which has deviated from the OECD's approach. Based on economic data, it is contended that Brazil has been able to design a tax system enabling it to tackle BEPS successfully. This article presents the salient features of the Brazilian tax system as an alternative to the OECD's future proposals, assisting policymakers of other countries - mainly non-OECD members - to redesign their tax system in order to strengthen the legal mechanisms that protect their respective tax bases.
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