Blazej Kuzniacki

Ministry of Finance of Poland

Deputy Director at Income Tax Department

Warsaw

Poland

SCHOLARLY PAPERS

5

DOWNLOADS
Rank 38,241

SSRN RANKINGS

Top 38,241

in Total Papers Downloads

1,100

CITATIONS

0

Ideas:
“  My current research project examines the reasons and the possibility to develop and execute the artificial intelligence technology assisting in international tax avoidance cases (AI tax assistance) that are covered by the principal purposes test (PPT). The AI could be primary based on the treaty abuse algorithm stemming from fact patterns, as recognized under BEPS action 6 and case law in various countries, and other relevant sources of interpretation of the PPT and other tax law. The AI's tax assistant could be expanded to deal with other international tax avoidance cases, such as those under the general anti-avoidance rule (GAAR) in the Anti-tax avoidance directive. More generally, my interests concern the appropriate way of interpreting tax law, the use of tax treaties by taxpayers (BEPS action 6/MLI) and associated issues. It is also pivotal to me to analyse BEPS action 3 - Designing Effective Controlled Foreign Company Rules and Anti-tax avoidance directive.  ”

Scholarly Papers (5)

1.

CFC Rules, BEPS Action 3 (Draft), and EU Law

WU International Taxation Research Paper Series No. 2015-21
Number of pages: 25 Posted: 17 Sep 2015
Blazej Kuzniacki
Ministry of Finance of Poland
Downloads 376 (76,240)

Abstract:

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2.

Preventing Tax Arbitrage via Hybrid Mismatches: BEPS Action 2 and Developing Countries

WU International Taxation Research Paper Series No. 2017-03
Number of pages: 48 Posted: 28 Mar 2017 Last Revised: 04 Apr 2017
Ministry of Finance of Poland, Bocconi University, Université Paris I Panthéon-Sorbonne - Sorbonne Law School, Universidad de la República, Colombian Tax Institute, University of Sao Paulo (USP), University of Cape Town (UCT), Vienna University of Economics and Business and University of Oslo
Downloads 344 (84,654)

Abstract:

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Hybrids, BEPS, Action Item 2, Mismatch, Developing Countries, Tax Arbitrage, Tax Governance, Sustainability

3.

The Marriage of Artificial Intelligence and Tax Law: Past, Present, and Future

Number of pages: 9 Posted: 11 Feb 2019
Blazej Kuzniacki
Ministry of Finance of Poland
Downloads 237 (126,001)

Abstract:

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AI, Tax Law, Business, Technology, Innovation, Algorithms

4.
Downloads 143 (198,712)

Abstract:

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domestic tax law, comparative tax law, international tax law, European tax law, BEPS, ATAD, tax policy, tax avoidance

5.

The Artificial Intelligence Tax Treaty Assistant: Decoding the Principal Purpose Test

Posted: 29 Aug 2018 Last Revised: 10 Sep 2018
Blazej Kuzniacki
Ministry of Finance of Poland

Abstract:

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OECD, BEPS, tax avoidance, AI, machine learning, technology, disruption, international