I have been doing research on the topic of environmental taxation for almost a decade, and have produced numerous publications calling for further regulation within the realm of international taxation. In my doctoral thesis, I propose a Multilateral Carbon Tax Treaty that would tax carbon on an extractive basis, and account for the in natura consumption of carbon rich by-products by taxing carbon at the earliest possible moment. In the fossil fuel production chain, for example, that would be at the upstream level.

This is an under-regulated and under-researched topic that is, nevertheless, of strategic importance for the implementation of the objectives of the United Nations Paris Agreement. The proposal for a multilateral carbon tax treaty (MCTT) is novel, in that it draws a proposed carbon tax rate and tax base from existing country practice, and derives a system for multilateral taxation from the existing environmental agreements, such as the United Nations Framework Agreement on Climate Change and the Paris Agreement. The thesis demonstrates how the MCTT would fit into the existing environmental legal framework, as well as in the international trade framework (through the WTO). The thesis delves on all the potential legal problems that might arise from the administration of a multilateral excise tax, and makes design recommendations, that are indispensable for the tax to be admitted from the environmental, fiscal and trade perspectives.

Several agencies have attempted to define environmental taxes without building a coherent normative conceptual framework which would differentiate between environmental policies that are driven by an environmental purpose and pursue an environmental effect, and policies that are mere revenue raisers, and are ineffective at promoting a behavioural change.

The failure to distinguish policies for what they are has made it difficult both to monitor countries’ environmental tax policies, and to provide clear guidance to new entrants in the environmental tax world, as to the best policies to pursue according to the envisaged goal. In past papers, and under the auspices of the UN Subcommittee on Environmental Taxation, I have proposed to make a conceptual distinction between environmental taxes and environmentally related taxes, according to whether the tax has an environmental purpose and effect. Setting environmental taxes apart from environmentally related taxes is important in order assess how effective countries are in administering policies that are effective in reducing carbon-based emissions, and other forms of polluting emissions. I have therefore come up with a unique “environmental tax” definition which is initially applicable only to carbon taxes, but that could be extended to other types of taxes containing the key characteristics to fulfill the objectives of the Paris Agreement:

“an environmental tax is a tax imposed for environmental reasons, whose tax base is a physical unit that has a proven specific negative impact on the environment. The term “environmental tax” is to be exclusively employed towards an excise capable of conferring a reduction in corresponding carbon-based emissions into the atmosphere. It is thus regarded to have environmental purpose and effect.”

This is the definition adopted by the Multilateral Carbon Tax Treaty, the text of which is contained at the end of the thesis, and made publicly available in this website for consultation. I am awaiting publication of my dissertation in book form in the IBFD doctoral series (expected in January 2019). Currently, my thesis can be consulted at the library of the Vienna University of Economics and Business.

Very little research has been conducted using developing country data and taking into account the economic constraints faced by these countries. The proposed MCTT builds on legislative proposals coming out of those countries, and explores how one might go about in setting a price for carbon that is compatible with the country’s level of economic development, while taking into account other political considerations. This is, in a nutshell, the object of my current research.

2018 - present 

Policy Leaders Fellowship, European
University Institute (EUI), School of Transnational Governance, 

Focus: environmental taxation

2018 – present 

Muenster University, Germany
-Schumann Fellowship for younger Scholars
-Focus: digital economy

2018 – present

Consultant to the Development Policy and Analysis Division, United Nations
-Lead author of the tax chapter of the World Economic and Social Survey.
-Focus: AI, digital economy, automation of taxes

2018 – present

Visiting Professor, Fundação Getúlio Vargas (São Paulo)
-Long-distance cooperation agreement to promote research on aspects of digitization.
-Focus: taxation of cryptocurrencies, blockchain, financial transactions, impacts in Brazil and other developing countries

2017 – present

Consultant in International Tax Law
-Provides independent expert advice in international taxation to government agencies, NGOs, and members of the industry.
-Consultant at the Vienna Institute for International Dialogue and Cooperation (VIDC) – environmental taxation
-Consultant, International Labour Organization, Global Commission on the Future of Work (impacts derived from digitalization)
-Select government appointments – capacity building – international taxation.
-Capacity Development trainer and tax Expert to Centro Interamericano de Administración Tributaria (CIAT).
-Columnist, Tax Notes International (Thompson Reuters)


2016 -2017

Economic Policy Adviser, United Nations
(fixed-term contract)
-Secretariat of the Tax Committee of Experts
-Lead role co-chairing Subcommittee meetings
-United Nations Tax representative in international tax conferences, academic meetings and professional conferences
-Lead role advising developing and emerging economies; finding compromise solutions with developed countries
-Contributor, co-writer and editor of the 2017 version of the UN Model Tax Treaty, the 2017 Transfer Pricing Manual, and the 2017 Handbook on Extractive Industries
-Author of papers and Articles for consideration of the Tax Committee of Experts
-Lead author of the Development Resource Mobilization chapter, of the Inter-Agency Task Force Report
-Lead fund-raiser at campaign to obtain donations to the work of the Committee of Experts

2014 - 2016

International Policy Manager, International tax policy and controversy department, Ernst & Young
-Managed working groups intended to conceive, draft and implement select tax legislation.
-Liaised public bids with the World Bank, OECD, and with EMEIA countries
-Drafted legislative change in EMEIA countries
-Monitored international tax legislation and forecasted change
-Produced tax leadership policy advise
-Liaised with Regional policy leaders to produce centralised thought leadership
-Lead role building transactional structures with the Brazilian and Latin American desks.

2011 - 2014

Research Fellow, International Bureau of Fiscal Documentation
(fixed-term contract)
-Represented IBFD in international tax conferences
-Worked towards completion of doctoral thesis, sponsored by the IBFD, at Wirtschaftsuniversität Wien (Vienna University of Economics and Business).
-Lecturer at the IBFD Tax Academy
-Capacity development missions in Latin America, Central America and Asia.
-Author of numerous publications
-Speaker at the BEPS Project open Consultation Meetings (numerous topics)

2010 - 2011

Senior Associate, Machado Associados (law firm)
-Launched affiliate office of Machado Associados, in Rio de Janeiro
-Lead acting lawyer in Rio de Janeiro
-Prospected new clients and managed office in Rio de Janeiro
-Focus: oil and gas and infrastructure projects
-Led bid over 1bn USD

2010 – 2011

Tax and Trade Policy Consultant, Intersul, Brazilian Ministry of Foreign Affairs
-Lead policy expert in project for facilitation of commerce between South American countries through integration and harmonization of tax, labour and environmental law.
-Speaker at launch event and regional meetings to harness support from South American countries
-Focus: Tax and Trade Law (WTO)

2009 - 2010

Consultant, Economic Policy, United Nations
(fixed-term appointment)
-Adviser and main contributor to the work of the UN Committee of Experts, secretariat role
-South-south Tax Cooperation Unit Leader
-Contributor to first version of UN Transfer Pricing Manual, Brazilian Expert
-Speaker in UN Subcommittee Meetings
-Author policy and technical papers for consideration of the Committee of Experts

2007 – 2007

Tax Lawyer, Tostes Associados (Law Firm)
Supervised group of 10 employees
Customs, tax and trade focus
Transactional focus.

2002 - 2006

Tax Lawyer, Pinheiro Neto Advogados (Law Firm)
-Focus: Transactional work, mergers and acquisitions, tax restructuring, Public bids, tax audits
-Supervisory role
-Emphasis on oil and gas, and infrastructure projects
-Customs and trade expertise

• Master class at Université Science Po, “The work of the United Nations Committee on International Tax Coordination” November 2018, Paris (forthcoming)
• Speaker at the International Bar Association Annual Conference, “The ever-increasing challenges to infrastructure development and financing in the resource and energy sectors” 8 October 2018 (forthcoming)
• Speaker at the Global Conference on Environmental Taxation (CGET), “The United Nations work on Environmental Taxation” 26-29 September, 2018 (forthcoming)
• Speaker at the 2^nd United Nations Subcommittee Meeting on Environmental Taxation, 19-20 September 2018, Paris (forthcoming)
• Nominated IFA General Reporter, Plenary Subject 2, “Exchange of information: issues, use and collaboration (CbC, Master file) and the attorney client privilege principle” (IFA 2020 Annual Congress in Cancun).
• Speaker at the International Labour Organization (ILO) Policy Dialogue No. 3: “Leveraging Big Data, Algorithms, AI, Blockchain and other Digital Technologies for Decent Work and Sustainable Enterprises” presented within the framework of the Global Commission on the Future of Work, San Francisco, USA, 27 April 2018.
• Speaker at the Expert Group Meeting of the United Nation’s World Economic and Social Survey (WESS) 2018 Report, “Emerging Technologies and Sustainable Development”, United Nations Headquarters, March 19 and 20 2018.
• Speaker at the International Fiscal Association (IFA) Mexican Branch Meeting on the new articles introduced by the 2017 update of the United Nations Model and the Digitalization of the Economy: Implications for the Mexican Tax Administration, 14 March 2018.
• Speaker at the Online Virtual Tax Summit, on the digitalization of the Economy, 13 March 2018.
• Speaker and presenter at the first meeting of the United Nations Subcommittee on Environmental Taxation, European Commission, Brussels 5 and 6 of March 2018.
• Speaker at the OECD open consultation meeting on the digital economy. Contributed an opinion on the ways through which the current international tax framework may be reformed in view of the digitalization of the economy (San Francisco, 1 November 2017).
• Member of the Subcommittee on Environmental Taxation: Issues for developing countries (October 2017 – and following).
• Speaker at the 15th Session of the Committee of Experts, proposing environmental taxation as a topic for further analysis by the Committee. The topic was accepted by the Committee and a Subcommittee on Environmental taxation was formed (October 2017).
• Speaker at the 2017 conference organize by the Independent Commission for the Reform of International Corporate Taxation (ICRICT), side-event organized parallelly to the United Nations General Assembly meeting. Spoke about the Brazilian Transfer Pricing Issues (September, 2017).
• Speaker and UN representative at the roundtable organized by Thompson Reuters on occasion of the 2017 IFA conference.
• Interview granted to Thompson Reuters during the IFA 2017 conference.
• Speaker at the plenary Session of the IFA 2017 conference, in the panel on “Recent Developments in International Taxation”
• United Nations Representative at the International Fiscal Association’s Permanent Scientific Committee Meeting, September 2017.
• Speaker at the Joint Meeting of Colombia and USA Branches of the International Fiscal Association “Recent Topics in International Taxation and Colombian Accession to the OECD,” August 2017.
• Presented the work of the Committee of Experts at the International Tax Compact Conference, 12-16 June, Berlin.
• Nominated IFA Country Reporter, Plenary Subject A, “Anti-avoidance measures of general nature and scope – GAAR and other rules” (IFA 2018 Seoul Conference).
• Speaker at the 4th Vienna Multi-Stakeholder Group on Improving Cross-Border Dispute Resolution (8-9 may, 2017), Vienna University of Business and Economics (WU).
• Served as secretariat at the 12th, 13th and 14th Sessions of the Committee of Experts – assisted in the presentation of outcomes of the Subcommittee on Mutual Agreement Procedure, and co-presented on the topic of environmental taxation during the 14th Session.
• United Nations Representative at the International Fiscal Association’s Permanent Scientific Committee Meeting, September 2016.
• Secretary and panel member of the IFA Seminar B Panel on Taxation of expatriates, September 2015.
• Speaker at the OECD Public consultation meeting on transfer pricing, Action 10, March 2015. Spoke about the 6th method for commodity trading.
• BEPS Monitoring Group representative and speaker at the OECD Tax and Development Meeting, March 2015.
• IFA Poster Programme Presenter, October 2014.
• Speaker at the OECD Public Consultation on Transfer Pricing Issues, Actions 8, 9 and 10 of the BEPS Programme, OECD, 19 and 20 May. Explained to the committee the importance of having a method such as the sixth method in the transfer pricing regulations.
• BEPS Monitoring Group representative and speaker, Task Force meeting on Tax and Development, OECD, 18 May 2015.
• Speaker at the 15^th Global Conference on Environmental Taxation (CGET), on the topic of environmental tax instruments to curb carbon emissions; Copenhagen, Denmark, September 2014.
• Speaker at the Low Carbon Earth Summit, Environmental policy instruments, Qingdao, China, September 2014.
• Speaker at OECD Consultation Meeting, Tax Aspects of the Digital Economy, BEPS Project, April 2014.
• Speaker at OECD Consultation Meeting on Abuse of tax Treaties, BEPS Project, April 2014
• Speaker at the OECD High Level Regional Consultation Meeting on BEPS and Automatic Exchange of Information – Consultation with South American Countries, Bogota, February 2014.
• Presenter at the IBFD’s Research Student Meeting, May 2014 – Doctoral student meeting to present the topic of her PH.D dissertation: “Putting a Charge on Carbon: A Proposition for a Model Carbon Tax Treaty.”
• In-house lecturer for a course administered by Expatise in association to the IBFD, on Federal and Social Security Taxation in Brazil. Course ministered in Amsterdam with videoconference to London and New York.
• Speaker at Taller “Desafíos para la implementación del control tributario de precios de transferencia en Centroamérica, Panamá y la República Dominicana,” digressing on the Brazilian Transfer Pricing System. Organized jointly by the Guatemalan Public Finance Ministry, ICEFI and the Guatemalan branch of the German Development Bank (GIZ), 26 November 2012.
• IBFD International Tax Academy (ITA) course Lecturer on “Principles of International Taxation” covering the topic of “Employment Income,” 8-10 October, 2012.
• IBA 2012 annual conference, speaker at the Public Law Committee entitled: “Beyond the Tipping Point: Is Mankind Populating itself to extinction?” Title of the presentation: “Is the World in Need of a Carbon tax?” 30 September – 5 October 2012.
• University of British Columbia, Speaker at the 13th Global Conference on Environmental Taxation: “Environmental Taxation: Barriers, Opportunities, and the Potential for Inducing Technological Innovation” September 20-22, 2012, Vancouver, BC, Canada.
• Poster Programme Presenter at the EATLP annual Conference (A Proposition for a Multilateral Carbon Tax Treaty), 2012.
• Speaker at a conference entitled: “Transfer Pricing: Alternative Methods of Taxation of Multinationals;” on the proposition for the Brazilian Transfer Pricing System, as an alternative to the OECD arm’s length standard. Conference organized by the Tax Justice Network, KEPA and Finland’s Ministry for Foreign Affairs, 13-15 June 2012.
• Speaker at the Public Law Committee Conference in 2012, IBA Annual Conference in Dublin.
• Awarded IBFD Research Fellow Grant, to sponsor the Ph.D in International Environmental Tax, Vienna Univeristy of Economics and Business (WU), Austria (Ph.D, 2016)
• Awarded Public Law Scholarship for the IBA 2012 Annual Conference in Dublin, November 2012
• Awarded Public Law Scholarship for the IBA 2011 Annual Conference in Dubai, November 2011.
• Guest Speaker at the Public Law Committee Conference in the 2011 IBA Annual Conference in Dubai – panel entitled “Impact of the Global Economic Meltdown on The Modern Welfare State,” November 2011.
• Speaker at the New York State Bar Association’s 2011 International Chapter Annual Meeting in Panama. Panel: “Utilizing Tax Incentives for Infrastructure Ventures in Latin America,” September 2011.
• Lectured on the “Principle of Non Discrimination under the Free Trade Agreements currently in force in Latin America” during the 2010 International Conference on Selected Issues of Discrimination, in the Czech Republic. Conference organized by the European Community in partnership with the University of West Bohemia.
• Speaker at the United Nations Subcommittee Meeting on transfer Pricing, on the Brazilian Transfer Pricing Rules, January 2010, UN Headquarters, New York.
• Awarded Wallace Scholarship, to attend New York University, USA, LL.M 2008
• Board Member, Cambridge Student Law Review (“CSLR”), editor and treasurer
• European Community Council, Research appointment, November 2007, Brussels, Belgium
• Awarded Shell Centenary Scholarship, Commonwealth Overseas Fund, to attend Cambridge University, LL.M 2007.