Spiritus Ex Machina: Addressing the Unique BEPS Issues of Autonomous Artificial Intelligence by Using 'Personality' and 'Residence'

INTERTAX. Volume 47, Issue 5. Alphen aan den rijn: Kluwer Law International, 2019.

Posted: 12 Jan 2019 Last revised: 6 Apr 2019

See all articles by Lucas de Lima Carvalho

Lucas de Lima Carvalho

University of Sao Paulo (USP), Faculty of Law (FD), Department of Economic, Financial, and Tax Law

Date Written: January 2, 2019

Abstract

This article analyses two unique BEPS issues associated with the future operations of Autonomous Artificial Intelligence (AAI), namely, "disappearing income" and "powerlessness to tax". AAI is defined as an AI system that (i) is capable of performing tasks commonly associated with human intelligence and beyond, (ii) is not directly or indirectly controlled by human beings, and (iii) has full managerial power over its own actions and resources. The paper provides policy recommendations to address the BEPS issues associated with AAI, as well as comments on their impacts for tax administration and the broader structure of domestic and international tax law.

Keywords: Artificial Intelligence, BEPS, Personality, Personhood, Residence, Robot, Singularity

JEL Classification: K33, K34, O31, O33

Suggested Citation

Carvalho, Lucas de Lima, Spiritus Ex Machina: Addressing the Unique BEPS Issues of Autonomous Artificial Intelligence by Using 'Personality' and 'Residence' (January 2, 2019). INTERTAX. Volume 47, Issue 5. Alphen aan den rijn: Kluwer Law International, 2019. . Available at SSRN: https://ssrn.com/abstract=3306427 or http://dx.doi.org/10.2139/ssrn.3306427

Lucas de Lima Carvalho (Contact Author)

University of Sao Paulo (USP), Faculty of Law (FD), Department of Economic, Financial, and Tax Law ( email )

Largo São Francisco, 95 Prédio Anexo
São Paulo
Brazil

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