Originally Posted by
KARFA
a journey of LHR-GRU-LHR starts in Brazil now does it?
ANAC res 138 doesn't limit scope to journeys originating in Brazil. It lists that as within scope then says 'And flights operated by national and international airlines domestically and internationally'. That's actually a literal translation of the scope. The scope is the second article by the way.
ANAC 400 isn't limited to journeys originating in Brazil, why would the intention of 138 be different?