Blazej Kuzniacki

Lazarski University

Świeradowska 43 Warszawa

Warsaw, 02-662

Poland

SCHOLARLY PAPERS

11

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Ideas:
“  Being inspired by my international life in academia and practice connected with international tax law and global investment regime, I render advice, second and expert opinions to clients and to other advisors on corporate income tax, EU and tax and investment treaty matters. Academically, you can read around 100 publications of mine, including four monographs, among which some of them were awarded with prestigious awards such as The 2023 IFA Mitchell B. Carroll Prize. I am also an experienced law faculty member at various universities and an international tax industry expert with over 10 years of researching, teaching and supervising in the classroom and online in the area of international tax law.Over the past four years, I have immersed myself in the multidisciplinary field of international tax law and global regime for investment, giving particular attention to the impact of fiscal misconducts of States oo cross border investments.  ”

Scholarly Papers (11)

1.

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

Number of pages: 9 Posted: 11 Feb 2019
Blazej Kuzniacki
Lazarski University
Downloads 903 (49,771)
Citation 4

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

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
Lazarski University, International Bureau of Fiscal Documentation (IBFD), Université Paris I Panthéon-Sorbonne - Sorbonne Law School, Universidad de la República, Colombian Tax Institute, University of São Paulo (USP), International Bureau of Fiscal Documentation (IBFD), International Bureau of Fiscal Documentation (IBFD) and University of Oslo
Downloads 743 (64,806)

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

3.

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
Lazarski University
Downloads 557 (93,298)

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4.

Pillar 2 and International Investment Agreements: ‘QDMTT Payable’ Seals An Internationally Wrongful Act

Tax Notes International
Number of pages: 21 Posted: 07 Nov 2023
Blazej Kuzniacki
Lazarski University
Downloads 458 (118,368)

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pillar two, international investment agreements, rule of law, good faith, internationally wrongful act, OECD

The Principal Purpose Test (PPT) in BEPS Action 6 and the MLI: Exploring Challenges Arising from Its Legal Implementation and Practical Application

World Tax Journal
Number of pages: 62 Posted: 14 Mar 2024 Last Revised: 25 Mar 2024
Blazej Kuzniacki
Lazarski University
Downloads 263 (215,425)

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tax treaties, abuse of law, principal purposes test, BEPS, VCLT, interpretation, prevention of tax avoidance

The Principal Purpose Test (PPT) in BEPS Action 6 and the MLI : Exploring Challenges Arising from its Legal Implementation and Practical Application

In: World tax journal. - Amsterdam. - Vol. 10 (2018), no. 2 ; p. 233-294
Posted: 06 Dec 2022
Blazej Kuzniacki
Lazarski University

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principal purpose test, BEPS Project (OECD), MLI, tax treaty, treaty abuse, treaty shopping

6.

Identification of the Factors (Variables) Relevant for the Artificiality Test Under the EU General Anti-Avoidance Rule and Their Basic Dichotomy

A Guide to the Anti-Tax Avoidance Directive, Elgar Tax Law and Practice series, 2020, ISBN: 978 1 78990 576 2
Number of pages: 8 Posted: 11 Nov 2020
Blazej Kuzniacki
Lazarski University
Downloads 121 (426,714)

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Tax Avoidance, GAAR, ATAD, EU, OECD, AI

7.

Tax and Non-Tax-Related Challenges of Pillar 2 for Non-Advanced Economies

Tax Notes International
Number of pages: 19
Blazej Kuzniacki
Lazarski University
Downloads 22

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Pillar Two, developing countries, tax incentives, OECD, UN, subsidies and grants, investment treaties, trade treaties, tax policy.

Aggressive Tax Planning in Light of the Securing the Activity Framework of Enablers Initiative: A Path to Inflation of Anti-Tax Avoidance Rules in the EU Law

International Tax Studies (ITAXS) 1/2023
Posted: 13 Jan 2023 Last Revised: 13 Feb 2023
Blazej Kuzniacki
Lazarski University

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tax law, tax avoidance, tax intermediaries, anti-tax avoidance rules, inflation of legislation

Aggressive Tax Planning in Light of the Securing the Activity Framework of Enablers Initiative: A Path to Inflation of Anti-Tax Avoidance Rules in the EU Law

In: International Tax Studies (ITAXS). - Amsterdam. - Vol. 6 (2023), no. 1 ; 22 p.
Posted: 07 Mar 2023
Blazej Kuzniacki
Lazarski University

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aggressive tax planning, anti-avoidance, tax shelter, intermediary, economic substance, ATAD, rule of law, BEPS Project (OECD), hybrid mismatch, SAAR

9.

Towards eXplainable Artificial Intelligence (XAI) in Tax Law: The Need for a Minimum Legal Standard

In: World tax journal. - Amsterdam. - Vol. 14 (2022), no. 4 ; p. 573-616
Posted: 10 Jan 2023 Last Revised: 11 Jan 2023
Lazarski University, European University Institute, Department of Law (LAW), affiliation not provided to SSRN, affiliation not provided to SSRN, affiliation not provided to SSRN and affiliation not provided to SSRN

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artificial intelligence, taxpayer rights, tax compliance

10.

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

Posted: 29 Aug 2018 Last Revised: 10 Sep 2018
Blazej Kuzniacki
Lazarski University

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

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