Ideas:
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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.
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