Blazej Kuzniacki

The Amsterdam Centre for Tax Law (University of Amsterdam)

Senior Research Fellow

Amsterdam

Poland

SCHOLARLY PAPERS

6

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SSRN CITATIONS

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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 (6)

1.

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

Number of pages: 9 Posted: 11 Feb 2019
Blazej Kuzniacki
The Amsterdam Centre for Tax Law (University of Amsterdam)
Downloads 614 (53,266)
Citation 2

Abstract:

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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
The Amsterdam Centre for Tax Law (University of Amsterdam), Bocconi University, Université Paris I Panthéon-Sorbonne - Sorbonne Law School, Universidad de la República, Colombian Tax Institute, University of São Paulo (USP), International Bureau for Fiscal Documentation (IBFD), Vienna University of Economics and Business and University of Oslo
Downloads 531 (63,993)

Abstract:

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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
The Amsterdam Centre for Tax Law (University of Amsterdam)
Downloads 440 (80,410)

Abstract:

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4.

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
The Amsterdam Centre for Tax Law (University of Amsterdam)
Downloads 76 (377,171)

Abstract:

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

5.

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

Posted: 29 Aug 2018 Last Revised: 10 Sep 2018
Blazej Kuzniacki
The Amsterdam Centre for Tax Law (University of Amsterdam)

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

6.

Controlled Foreign Companies and Tax Avoidance: International and Comparative Perspectives with Specific Reference to Polish Tax and Constitutional Law, EU Law and Tax Treaties

Posted: 01 Feb 2018 Last Revised: 04 Sep 2019
Blazej Kuzniacki
The Amsterdam Centre for Tax Law (University of Amsterdam)

Abstract:

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