Taxing Artificial Intelligence and Robots: Critical assessment of Potential Policy Solutions and Recommendation for Alternative Approaches

In recent years, investments in technology have resulted in an exponential growth of AI/robots. It is argued that some of these innovations are able to outperform and replace humans in various types of jobs. Accordingly, concerns regarding government revenues have been raised, as AI/robots could trigger widespread unemployment with the result that less tax revenue will accrue to the government. This contribution, as a start, analyses whether or not this is truly a concern. In order to do so, the authors map the Industrial Revolution(s) that humankind has witnessed and then conduct a literature review of economic and demographic studies relevant to the debate. The economic studies indicate two different directions, that is, some argue that AI/robots (Industry 4.0) will increase human jobs whereas others argue that jobs could disappear. At the same time, the demographic perspective indicates that a purely economic employment-focused view of AI/robots is bound to lead to inconclusive results. Assuming that this is a probable concern, the authors summarize selected measures taken by governments as well as the various options that have been considered in academic literature to introduce taxes on AI/robots. Subsequently, the authors analyse the various “taxing” options from the perspective of commonly accepted tax policy principles applicable to electronic commerce (Ottawa Taxation Framework conditions). This analysis indicates that several proposals (e.g. proposals that treat AI/robots as independently taxable subjects or proposals that attribute income to owners of AI/robots) breach the principles of (i) neutrality; (ii) simplicity and certainty; (iii) efficiency; (iv) effectiveness and fairness; and (v) flexibility. Thus, such measures should not be pursued. The authors also conclude that, at this stage, targeted taxes on AI/robots should not be introduced, as this would also be contrary to the measures taken by governments globally to promote research and development (R&D) (input or output incentives). The present contribution therefore suggests that governments need to be proactive rather than reactive in this area. This could be achieved by monitoring the impact of AI/robots on a regular basis, and if the trend indicates that jobs are disappearing or revenues are declining, then the article suggests that states raise funds from an earmarked education tax. The funds raised from this tax, among other objectives, should be used to finance and foster professional educational programmes to reskill workers, besides assisting and guiding them to transition into new roles. However, a national measure may not be sufficient to tackle the issue (issues) at stake, especially in light of the demographic perspective discussed in the contribution. Thus, considering some jurisdictions may not be in a position to implement or fully benefit from an education tax, the authors also discuss the possibility of implementing a global fiscal redistribution mechanism (multilateral solution) from developed (surrender jurisdictions) to developing countries (recipient jurisdictions). The latter, depending on its scope, could be in the form of a global education tax or more broadly a planetary tax

Забрана дискриминације у међународном опорезивању дохотка и имовине

Међународно опорезивање дохотка и имовине је нераскидиво везано за различит третман. Размере пореске обавезе, али и поступак опорезивања, зависе од тога да ли је порески обвезник резидент или нерезидент одређене државе. Извор прихода може утицати на њихов порески третман у случају резидентних обвезника, а порески подстицаји ће често бити усмерени само на оне случајеве који се могу повезати са јурисдикцијом чије их законодавство пружа.Мада су правила о забрани дискриминације у области међународног опорезивања дохотка и имовине присутнавеома дуго, тек у последњих неколико деценија добијају на значају, и то првенствено кроз праксу Европског суда правде (ЕСП) у тумачењу основних слобода у области непосредних пореза. Како је управо забрана дискриминације садржана у основи нових односа који се успостављају на нивоу Европске уније (ЕУ), Светске трговинске организације и других наднационалних творевина, које све више уређују свеобухватни живот планете, питање забране дискриминације у области међународног опорезивања дохотка и имовине којe се, на први поглед, чини тек посредно дотакнутo овим процесима, добија на свом значају. У оквиру ове докторске дисертације покушали смо да одговоримо на следећа кључна питања: · Шта представља дискриминацију у међународном опорезивању дохотка и имовине? · Када је и у ком обиму дискриминација забрањена у међународном опорезивању дохотка и имовине? · Да ли су постојеће забране дискриминације у међународном опорезивању дохотка и имовине сврсисходне и могу ли се побољшати? · Какав је значај правила о забрани дискриминације и на који начин она могу утицати на даљи развој међународног опорезивања дохотка и имовине, нарочито из перспективе српског пореског права.International taxation of income and capital is inseparably related to different treatment. The scope of tax liabilities, as well as procedural aspects of taxation, depend on whether the taxpayer is a resident or a nonresident of a particular country. The source of income may impact its tax treatment in the case of resident taxpayers, while tax incentives will be available only in cases which may be linked to the jurisdiction whose legislation provides them. Although non-discrimination rules in the area of international taxation of income and capital have been present for quite some time, it is only in the last few decades that they are gaining in relevance, primarily through the jurisprudence of the European Court of Justice (ECJ) in interpreting the application of the fundamental freedoms within direct taxation issues. As non-discrimination is at the core of the new relationships being established at the level of the European Union (EU), the World Trade Organization and other supranational creations, which increasingly dominate the overall life on our planet, the problem of non-discrimination in international taxation of income and capital, on first glance only indirectly impacted by these processes, becomes one of a fundamental importance. In this doctoral dissertation we have tried to answer the following key questions: · What represents discrimination in international taxation of income and capital? · When and in what scope is discrimination prohibited in international taxation of income and capital? · Do existing non-discrimination norms in international taxation of income and capital fulfill their purpose and can they be improved? · What is the relevance of non-discrimination rules and in what way can they impact the future development of international taxation of income and capital, particularly from the perspective of Serbian tax law

Causes and effects of financial crises in global economy

The scientific and professional public today often wonders why the Great depression (Krugman) from 1929 is relevant to all the crises which later occured, thus relevant to the financial crisis of 2008. Certainly there are reasons why the Great depression (breakdown) from 1929 isalso relevant tothe major crisis from 2008. In both cases the government knew what should be done. In both occasions it refused to do so. In the spring of 1929 several strict words from a high position, higher discount rates and determined investigation of pyramid schemes of the time could lead to the fall of house of cards on the Wall Streetbefore its fall destroyed the entire economy. In 2004 FBI warnОН tСО publТМ about “tСО ОpТНОmТМ oП publТМ ПrauНs”. OnМО aРaТn tСО РovОrnmОnt НТН notСТnР. AМtuallв, Тt НТН somОtСТnР аorsО, Тt alloаОН a combination of low interest rates, deregulation and clear signals that laws will not be obeyed. This only spread the fire. Originally, the current crisis is related to living space, where the problem was not the lack of it, but rather its abundance. Financial crises that took place during the 20th century, and especially during 1970s (official beginning of the globalization of the world economy) were consequences of the implosion of property prices or large depreciations of national currencies on the foreign exchange market. In some cases foreign exchange crises led to bank crises in other cases it was vice versa. Huge amounts of fictive capital that circle around the planet create a possibility to flood the market. The beginning of globalization is marked by instability and occasional crises. The markets of shares, goods, estate and oil are instable. Financial bubbles always explode, simply because by definition a bubble consists of an unsustainable pattern of changing prices and money

Neurophysiological evaluation of patients with degenerative diseases of the cervical spine

Bacground/Aim. Diagnostic protocol for patients with degenerative diseases of the cervical spine demands, in parallel with neuroimaging methods, functional evaluation through neurophysiological methods (somatosensitive and motor evoked potentials and electromyoneurography) aiming to evaluate possible subclinical affection of spinal medula resulting in neurological signs of long tract abnormalities. Considering diversities of clinical outcomes for these patients, complex diagnostic evaluation provides a prognosis of the disease progression. Methods. The study included 21 patients (48.24 ± 11.01 years of age) with clinical presentation of cervical spondylarthropathy, without neuroradiological signs of myelopathy. For each patient, in addition to conventional neurophysiological tests (somatisensory evoked potentials - SSEP, motor evoked potentials - MEP, electromyoneurography - EMG, nerve conduction studies), we calculated central motor conduction time (CMCTF), as well the same parameter in relation to a different position of the head (maximal anteflexion and retroflexion), so-called dynamic tests. Results. Abnormalities of the peripheral motor neurone by conventional EMNeG was established in 2/3 of the patients, correponding to the findings of root condution time. Prolonged conventional CVMPF were found in 29% of the patients, comparing to 43% CVMPF abnormalities found with the dynamic tests. In addition, the SSEP findings were abnormal in 38% of the patients with degenerative diseases of the cervical spine. Conclusion. An extended neurophysiological protocol of testing corticospinal functions, including dynamic tests of central and periheral motor neurons are relevant for detection of subclinical forms of cervical spondylothic myelopathy, even at early stages. In addition to the conventional neurophysiological tests, we found usefull to include the dynamic motor tests and root conduction time measurement in diagnostic evaluation

The perfect silence: An empirical study on how ignorance and lack of critical debate effect the process of enacting tax legislation in Serbia

In this paper the authors deal with the crucial question of the ability of the Serbian institutions and society to apply adequate scrutiny with respect to the enactment of tax legislation. After providing a description of the current Serbian law-making and public consultations framework, and analyzing the relevance of the transitional nature of the Serbian political environment on the approach to the business of legislating, the authors choose three case studies which lead to the conclusion that it is the lack of even basic knowledge regarding taxation, at the level of the members of parliament and the media, combined with the silence and inertness of Serbian professional circles to participate in public debates on tax policy, that is enabling many questionable norms to enter Serbian legislation without any notable opposition or deliberation. Finally, the authors propose certain measures that could improve the public consultations process

Legal certainty and taxation: The problem of retroactive interpretation

This article shows that the principle of legality of a tax norm is not exhausted in its 'source' component (i.e. that the norm is enacted by parliament) but also encompasses the 'content' element - a set of requirements for it to be deemed as good law. It is not just retroactivity of a law that is an issue, but legal certainty is also jeopardized by retroactive interpretation implying changes in interpretation of the same norm by authorities who understood it for a long period in a different sense. A threat to legal certainty also exists when a provision that was dormant for years is suddenly applied. A case study shows that the Serbian Parliament issued an authentic interpretation of a tax norm to assert essentially a different interpretation compared to the one well-established in the past, in order to solve a particular case, while a court used that interpretation to pass judgment in a pending case. Within the EU we find notable cases where not only are norms attributed a certain meaning from their inception, even though 60 years may have passed from their initial introduction to the possibility of the existence of a 'new meaning' being suggested for the first time, but taxpayers are made to suffer the consequences of the new interpretation. Had the legislator been able to pay more attention to the content of the bills and apply a more comprehensive approach to current issues, the legal certainty, in terms of avoiding 'innovative' retroactive interpretations, could be preserved

The first record of the Chinese pond mussel Sinanodonta woodiana (Lea, 1834) in Montenegro

Sinanodonta woodiana (Lea, 1834), Chinese pond mussel (Bivalvia: Unionoida: Unionidae) is one of the most invasive aquatic macroinvertebrate species found in Europe. We report the Chinese pond mussel for the first time in Montenegro, in August 2012, in Lake Šasko (Adriatic part of the Central Mediterranean subarea). One specimen of the Chinese pond mussel was observed in a habitat with a predominantly silt-clay substrate. The main pathway of species introduction was evaluated to be via fish stocking. [Projekat Ministarstva nauke Republike Srbije, br. III 43002 i br. ON 173025

Phenolics content and antioxidant capacity of commercial red fruit juices

The content of phenolics: total phenols (TP), flavonoids (TF), anthocyanins (TA) and hydroxicinnamic acid as well as the total antioxidant capacity (TAC) in nine commercial red fruit juices (sour cherry, black currant, red grape) produced in Serbia were evaluated. The total compounds content was measured by spectrophotometric methods, TAC was determined using DPPH assays, and individual anthocyanins and hydroxycinnamic acids was determined using HPLC-DAD methods. Among the examined fruit juices, the black currant juices contained the highest amounts of all groups of the phenolics and exhibited strong antioxidant capacity. The amount of anthocyanins determined by HPLC method ranged from 92.36 to 512.73 mg/L in red grape and black currant juices, respectively. The anthocyanins present in the investigated red fruit juices were derivatives of cyanidin, delphinidin, petunidin, peonidin and malvidin. The predominant phenolic acid was neoclorogenic acid in sour cherry, caffeic acid in black currant, and p-coumaric acid in black grape juices. Generally, the red fruit juices produced in the Serbia are a rich source of the phenolic, which show evident antioxidant capacity