APPLICATION OF MANDATORY DISCLOSURE RULES AND LEGAL CERTAINTY

This work analyzes mandatory disclosure rules (MDR) on tax planning under different perspectives, in order to find the most efficient solution when applying this kind of measure. One of the problems always raised in the application of mandatory disclosure rules is that the regime could increase the levelof uncertainty for taxpayers, when closing gaps and adjusting mismatches to avoid certain planning that are exploiting these deficiencies in the law. The topic analyzes legal certainty searching for a balance among principles, standards and rules, without denying the application of the principle.