🤖 This week’s issue of Tax Notes International features an article titled “Fraudulent AI as an Agent PE” and written by our founder, Lucas de Lima Carvalho. His piece explores the interplay between Art. 5(5) of the OECD – OCDE and United Nations Model Conventions, their references to “the principal role leading to the conclusion of contracts”, and the roles of social media influencers and malicious AI clones that might generate Permanent Establishment (PE) links in treaty partners.
The article is available here (https://bit.ly/3UfZlM6). If you are interested in the topic of taxation and its impact on new technologies, here is a list of recommended publications:
✅ “The ‘Principal Role’ of Social Media Influencers as PEs”, by Lucas de Lima Carvalho and Larissa Falkowski. Published by Tax Notes on November 22, 2021. Available at: https://bit.ly/3QkNdrS
✅ “Taxing Artificial Intelligence”, by Xavier Oberson. Published by Edward Elgar Publishing in 2024. Available for purchase at: https://bit.ly/44dLrid
✅ “Taxing Artificial Intelligence and Robots: Critical Assessment of Potential Policy Solutions and Recommendation for Alternative Approaches – Sovereign Measure: Education Taxes/Global Measure: Global Education Tax or Planetary Tax”, by Vikram Chand, Svetislav Kostic and Ariene Reis. Published by IBFD on December 22, 2020. Available at: https://bit.ly/4dfloes
✅ “Towards eXplainable Artificial Intelligence (XAI) in Tax Law: The Need for a Minimum Legal Standard”, by Błażej Kuźniacki, Marco Almada, Kamil T., Łukasz Górski, Beata Winogradska and Reza Zeldenrust. Published by IBFD in September of 2022. Available at: https://bit.ly/4b7UumM
✅ “Inteligencia artificial y tributación: el debate sobre la personalidad jurídica y la responsabilidad”, by Sonia Elizabeth Ramos-Medina. Published by Universidad Anáhuac México in 2023. Available at: https://bit.ly/4beA1wG (in Spanish)
✅ “Sentience as a Prerequisite for Taxing AI”, by Lucas de Lima Carvalho and Victor Guilherme Esteche. Published by Tax Notes on December 5th, 2022. Available at: https://bit.ly/3JCwv3B
✅ “Novas Tecnologias e a Tributação – O Uso da Inteligência Artificial Explicável (Explainable Artificial Intelligence – XAI) como Ferramenta de Fiscalização da Renda Gerada pelo Estabelecimento Permanente na Economia Digital”, by Vanessa Bulara. Published by IBDT – Instituto Brasileiro de Direito Tributário in 2023. Available at: https://bit.ly/3wal0gz (in Portuguese)
✅ “The use of Artificial Intelligence by tax administrations, a matter of principles”, by Cristina Garcia-Herrera Blanco. Published by Centro Interamericano de Administraciones Tributarias – CIAT. Available at: https://bit.ly/3JzB4vk
✅ “Will Robots Agree to Pay Taxes? Further Tax Implications of Advanced AI”, by Bret Bogenschneider. Published by University of North Carolina School of Law in 2020. Available at: https://unc.live/3xSa1Jb 🌍 🌎 🌏
