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


{46 Pages Posted: 12 Jan 2019 Last revised: 2 Feb 2019 }

Author: Lucas de Lima Carvalho ( University of Sao Paulo (USP), Faculty of Law (FD), Department of Economic, Financial, and Tax Law)


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.

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