§113. Considering that by this Treaty we can already extract the general juridical mechanisms which also constitutes the other Treaties closed by Brazil, let’s do a detailed and meticulous analyses on the Convention to Avoid Double Taxation and Regulate Other Issues in the Subject of Income Tax among the Federative Republic of Brazil and the Kingdom of Belgium:
"Decree nº 72.542, 30th July of 1973; Official Diary 8-2-73. Promulgates the Convention to Avoid Double Taxation and Regulate Other Issues in the Subject of Income Tax. Brazil Belgium.
Preamble:
The PRESIDENT OF THE BRAZILIAN REPUBLIC, having the NATIONAL CONGRESS approved, by the Legislative Decree nº 76, of December 1, 1972, the Convention to Avoid Double Taxation and Regulate Other Issues in the Subject of Income Tax among the Government of the Federative Republic of Brazil and the Government of the Belgium Kingdom, signed in Brasilia on July 23, 1972; having being the Instruments of Ratifying exchanged in Brussels on 23 July, 1973; and having the Convention, in compliance with its Article 28, geted in force on July 12, 193; the President decrees that this Convention, attached to this present Decree, shall be executed and fulfilled in all its terms. Brasília, July 30, 1973; 152º from the Independence and 85º of the Brazilian Federative Republic".
§114. This norm was amendment by the Decree nº 6.332, of December 28, 2007 (an Additional Convention), which one in its Article 2, of the Preamble, express:
“Are under approval of the National Congress any and all acts that can result in a revision of this Convention, as well as any complementary adjustments that (…) can result in burdensome charges or burdensome commitments to the national patrimony of Brazil”.
§115. Or, in other words, in Brazilian jurisdiction the Convention is protected by, and has as origin of its force, the National Legislative Power of Brazil (and not the Executive Power).
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