International environmental taxation and the development of policies that aim to curb carbon emissions on a cross-border basis; international trade regulations associated to environmental tax reform (application of WTO rules and the GATT in relation to national environmental tax policies such as Border Tax Adjustments); the interaction between environmental tax instruments and tax treaties.
The taxation of the digital economy; redefinition of international tax treaties in light of the digitalization of business; digitalization and domestic tax systems/effect on labour and social security; taxation of cryptocurrencies; digitalization and impact on implementation of United Nations Sustainable Development Goals (SDGs); development resource mobilization for poverty reduction.
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.
European University Institute (EUI), School of Transnational Governance, Italy Research area: Environmental Taxation 2018-201903.03.2019
Muenster University, Germany Director of Studies: Joachim Englisch 2018Learn More31.10.2018
Fundação Getúlio Vargas, Brazil Research area: Digitalization of the economy Remote appointment 201831.12.2018
Wirtschaftsuniversität Wien / Vienna University of Economics and Business, Austria Ph.D Thesis: A Proposition for a Multilateral Carbon Tax Treaty Supervisor: Michael Lang (co-supervisor: Frans Vanistendael) 2012 - 2016 IBFD Scholarship Fund/Research FellowshipLearn More18.11.2016
New York University, United States LL.M thesis: A Proposal for a Brazilian model tax treaty Supervisor: David Rosenbloom 2008-2009 Wallace Scholarship07.06.2009
Cambridge University, Darwin College, United Kingdom LL.M Thesis: Third-country relations with the European Community: a growing snowball: an analysis of the recent developments in the European Court of Justice's jurisprudence. Supervisor: John Tiley 2007-2008 Shell Future Leaders Centenary Scholarship Fund/Commonwealth Trust Fund30.06.2008
Instituto Brasileiro de Estudos Tributários (IBET), Brazil 2003-2005, summa cum laude30.06.2007
Universidade Cândido Mendes, Brazil Thesis: A Tributação da Exploração da Capacidade de Satélite (The Taxation of Exploration of Satellite Capacity) Supervisor: Corintho Falcão (co-supervisor: Gustavo Brigagão) 2000-2004, summa cum laude31.12.2004
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)
Economic Policy Adviser, United Nations
-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
-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
-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
2002 - 2006
Tax Lawyer, Pinheiro Neto Advogados (Law Firm)
-Focus: Transactional work, mergers and acquisitions, tax restructuring, Public bids, tax audits
-Emphasis on oil and gas, and infrastructure projects
-Customs and trade expertise
2005 Bar Association, Rio de Janeiro, Brazil
2007 - 2008 Shell Centenary Scholarship Fund for Future Leaders/Commonwealth Trust Fund
2007 - 2008 Cambridge Student Law Review (“CSLR”), Board Member
2008 - 2009 Wallace Scholarship
2008 International Fiscal Association Poster Programme
2011 – 2012 International Bar Association (IBA) Scholar, Fellow
2012 New York Bar Association
2011 - 2014 IBFD Scholarship Fund
2012 EATLP Poster Programme (A Proposition for a Multilateral Carbon Tax Treaty)
2014 IFA Poster Programme (A Proposition for a Multilateral Carbon Tax Treaty)
2014 Portuguese Bar Association
2017 Nominated IFA Country Country Reporter (Brazil) on plenary Subject A “Anti- avoidance measures of general nature and scope – GAAR and other rules” (IFA 2018 Seoul conference)
2018 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).
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In: Tax notes international. - Falls Church. - Vol. 91 (2018), no. 4 ; p. 367-372Read More
In: Tax notes international. - Falls Church. - Vol. 90 (2018), no. 12 ; p. 1273-1277Read More
In: Tax notes international. - Falls Church. - Vol. 91 (2018), no. 4 ; p. 367-372Read More
In: Tax notes international. - Falls Church. - Vol. 89 (2018), no. 10 ; p. 949-954Read More
In: Tax notes international. - Falls Church. - Vol. 89 (2018), no. 7 ; p. 623-628Read More
In: Tax notes international. - Falls Church. - Vol. 89 (2018), no. 2 ; p. 181-186Read More
in: 71 Bulletin for International Taxation 6 (2017), Journals IBFD.Read More
British Tax Review, n. 4, November 2017 (double peer review).
Vienna University of Business and Economics, 2016 (IBFD publication, forthcoming) available through the permalink: http://permalink.obvsg.at/wuw/AC13710313
Intertax Law Journal, Issue 11, Volume 45, pp. 688 – 700 (peer reviewed segment), October 2017
Peer reviewed section, Intertax, Volume 43, Issue 10, pp. 571-588, 2015.