Spiritus Ex Machina addressing the unique BEPS issues of autonomous artificial intelligence by using 'personality' and 'residence' Lucas de Lima Carvalho
By: Carvalho, Lucas de Lima
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Material type: 
ArticlePublisher: 2019Subject(s): INTELIGENCIA ARTIFICIAL | ROBOTS | FISCALIDAD INTERNACIONAL
In:
Intertax v. 47, n. 5, May 2019, p.425-443Summary: This article concerns the treatment of income earned by Autonomous Artificial Intelligence (AAI) in the field of international taxation. The author addresses the question whether the AAI schould be regarded as a 'person' under domestic law or tax treaties following either the OECD or the United Nations (UN) Model Convention. If so, should it be regarded as a 'resident person' of one or more contracting jurisdictions? The second chapter of the article provides definitions for AI and AAI, placing both phenomena in the field of the digital economy. In the third chapter, the author explains in detail the unique BEPS issues associated with AAI. Finally, in the fourth chapter, he provides policy prescriptions designed to delineate the 'personality' and the 'residence' of AAI under domestic law and under income tax treaties and to tackle the BEPS issues created by AAI that are related to the application of those two terms in international taxation.
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|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141/2019/5-2 (Browse shelf) | Available | OP 2141/2019/5-2 |
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| OP 2141/2019/4-7 General and specific anti-tax avoidance measures under recent tax reform in Greece | OP 2141/2019/5 Intertax | OP 2141/2019/5-1 Developments on the digital economy front | OP 2141/2019/5-2 Spiritus Ex Machina | OP 2141/2019/5-3 Debt push-downs in times of BEPS Action 4 and the ATAD | OP 2141/2019/5-4 The EU standard of good governance in tax matters for Third (non-EU) countries | OP 2141/2019/5-5 Open versus closed competence to tax |
Resumen.
This article concerns the treatment of income earned by Autonomous Artificial Intelligence (AAI) in the field of international taxation. The author addresses the question whether the AAI schould be regarded as a 'person' under domestic law or tax treaties following either the OECD or the United Nations (UN) Model Convention. If so, should it be regarded as a 'resident person' of one or more contracting jurisdictions? The second chapter of the article provides definitions for AI and AAI, placing both phenomena in the field of the digital economy. In the third chapter, the author explains in detail the unique BEPS issues associated with AAI. Finally, in the fourth chapter, he provides policy prescriptions designed to delineate the 'personality' and the 'residence' of AAI under domestic law and under income tax treaties and to tackle the BEPS issues created by AAI that are related to the application of those two terms in international taxation.
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