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1 First Meeting in the Multi-stakeholder Series “Blockchain: Taxation and Regulatory Challenges and Opportunities” Vienna, 15-16 March,2017 Room EA.0.024 (Building EA, ground floor); WU A Background Note Prepared by the WU / NET Team With blockchain, we can imagine a world in which contracts are embedded in digital code and stored in transparent, shared databases 1 , where they are protected from deletion, tampering, and revision. In this world, every agreement, every process, every task, and every payment would have a digital record and signature that could be identified, validated, stored, and shared. Intermediaries like lawyers, brokers, and bankers might no longer be necessary. Individuals, organizations, machines, and algorithms would freely transact and interact with one another with little friction. This is the immense potential of blockchain. Iansiti, Marco; Lakhani, Karim R. "The Truth About Blockchain" 2 . 1 Term ‚database’ is often substituted by more accurate term ‘distributed ledger’. 2 Iansiti, Marco; Lakhani, Karim R. "The Truth About Blockchain". Harvard Business Review. Harvard University, January 2017

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First Meeting in the Multi-stakeholder Series

“Blockchain: Taxation and Regulatory Challenges and Opportunities”

Vienna, 15-16 March,2017

Room EA.0.024 (Building EA, ground floor); WU

A Background Note Prepared by the WU / NET Team

With blockchain, we can imagine a world in which contracts are embedded

in digital code and stored in transparent, shared databases1, where they are protected from deletion, tampering, and revision. In this world, every agreement, every process, every task, and every payment would have a digital record and signature that could be identified, validated, stored, and shared. Intermediaries like lawyers, brokers, and bankers might no longer be necessary. Individuals, organizations, machines, and algorithms would freely transact and interact with one another with little friction. This is the immense potential of blockchain.

Iansiti, Marco; Lakhani, Karim R. "The Truth About Blockchain"2.

1 Term ‚database’ is often substituted by more accurate term ‘distributed ledger’. 2Iansiti, Marco; Lakhani, Karim R. "The Truth About Blockchain". Harvard Business Review. Harvard University, January 2017

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Blockchain Technology and Taxation

Blockchain and transformation Blockchain is one of the truly revolutionary technological breakthroughs of the past two decades3. It is anticipated that it will trigger phenomenal transformation4. As happened with Internet almost twenty years ago, Blockchain appears to be a foundation technology in that it enables one to reimagine a large variety of existing processes and interactions. It may have the potential to change the very fabric of society, bolstering the growth of an ecosystem that replaces traditional mechanisms with modern, more relevant infrastructures, adequate and befitting to the highly digitalised and virtualised world. Blockchain emerged out of the rubble of the financial crisis of 2008, global destabilisation of economies and unprecedented efforts by governments to rescue financial institutions that were responsible for causing the crash in the first place. Such measures eventually led to a breakdown of public trust in the financial institutions and in governments as guardians of the best interests of society as a whole. Several years later, despite numerous national and supranational efforts, the global economy is still characterised by high levels of debt and anaemic growth. Governments are struggling to find suitable solutions to the challenges posed by the combination of highly mobile capital, deregulation and lower tariffs, globalisation, digitalisation, high-frequency trading, and securing their revenue base One of the unlikely solutions to these difficulties was originally proposed in a now legendary White Paper called Bitcoin: A Peer-To-Peer Electronic Cash System5, published by a person or persons going by the name Satoshi Nakamoto just a few weeks following the collapse of Lehman Brothers, which triggered the global crisis. The paper essentially questioned the need for intermediary institutions to facilitate transactions of value between two parties. It argued that the central function of financial institutions is to reduce any uncertainty from arising when an online payment is made between two unrelated parties, by guaranteeing the authenticity of the transaction. However, if such authenticity could be encrypted into the transaction itself, then the financial institutions’ role 3 See for example: Kate Barton, Three Tax Mega Trends to Watch in 2017, Bloomberg BNA, Daily Tax Report (10 DTR J-1, 1/17/17), 2017. Blockchain was identified as a disruptive mega-trend along with Artificial Intelligence (AI) and Robotics Process Automation (RPA). 4 Blockchain technology has a potential to transform the ‘Internet of Information’ where main unit of exchange is information (email, social media, etc) to the ‘Internet of Value’, which will exchange units of value, such as cryptocurrencies and Smart Contracts. Due to its transformative effect, the Blockchain is referred to as foundational technology. See, for example, Richard T. Ainsworth, Payroll Tax and Blockchain, (to be published) 5 Satoshi Nakamoto, Bitcoin: A Peer-to-Peer Electronic Cash Payment System, www.bitcoin.org

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would be replaced by an ‘electronic payment system based on cryptographic proof instead of trust, allowing any two willing parties to transact directly with each other without the need for a trusted third party’6. The unit of value with embedded encrypted proof was called a Bitcoin, and the transaction framework in which it would operate is now referred to as Blockchain.

Blockchain mechanism

Structurally, a blockchain is a network that timestamps transactions by hashing (an indelible stamping mechanism) them into an ongoing chain of transaction grouping or blocks, each containing new information plus a hash of the prior block. This chain of blocks is secured by encryption proofs which currently use enormous computing power of distributed servers which compete to get paid to validate and process transactions, known as “mining”. As an example, currently Bitcoin miners deploy more compute power that the top 500 supercomputers in the world, and get paid over $1 million per day for doing so. Since anyone seeking to take control of the blockchain to overriding rules or rewrite history would need to possess at least 51% of the computational power, blockchains are secured both technically and economically via this crypto-economic incentive system. The final element is a “consensus” mechanism whereby transactions are affirmed as valid based upon the coded rules running simultaneously on the thousands of computers involved. The blocks of transaction data, hashing and consensus functions come together to form a decentralized ledger system consisting of a rule execution engine and database of all transactions, creating an immutable audit trail with high level of protection against corruption7. Functionally, the result is two main characteristics which can be attributed to the blockchain technology: elimination of the intermediary party and generation of immutable, distributed ledger. Blockchain and Use of Intermediaries

Currently, an overwhelming majority of the papers published about possible uses of Blockchain technology address the issues pertaining to the first characteristic – embedded encryption proof, which questions the need for a third party providing verification – which is highly relevant, but by no means restricted to financial institutions. Transaction costs arising from the interposition of an intermediate party between transacting parties can be significantly reduced, or removed altogether, given an alternative trustworthy validation mechanism. That mechanism is an encryption algorithm that makes use of phenomena created within the digital realm and provides an entirely new model of financial markets. It is commonly perceived as highly disruptive, as it questions a core element of the value proposition of financial intermediaries as they operate today.

6Ibid. 7 https://www.youtube.com/watch?v=Lx9zgZCMqXE

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Although the financial markets are at the forefront of development, implementation and experimentation with new technology, the test results derived would be applicable primarily in the situations involving a peer-to-peer transaction of value. Thus use of cryptocurrency and /or Smart Contracts that are coded to self-execute upon certain triggers are highly relevant to the market-based transactions, such as online trades, financial transactions, capital markets or any other instances of value exchange. Within the context of blockchain, these technological developments impact primarily execution of transactions without relying on intermediary.

Blockchain and Distributed Ledgers

The second characteristic of the blockchain technology – creation of immutable distributed ledgers –provides immense opportunities for application to a great variety of domains, particularly in the government sector, which rely primarily on assimilation and use of data as a foundation for execution of their functions.

Blockchain is a unique, highly sophisticated way to produce a simple output: a system of ledgers where transactions are recorded in a decentralised fashion creating a transparent audit trail virtually immune to corruption and falsification8. The possibility of creating decentralised distributed ledgers, which record and store transactions making them traceable and transparent, opens a world of possibilities. Like the Internet, the system of distributed ledgers would be operated in virtual domain surpassing physical borders and updated by independent authorised parties, so, no matter where transaction occurs, it is logged and recorded as a block on the Blockchain.

Blockchain: Opportunities and threats to tax administration

Lack of fragmentation of information, as well as inherent reliability of records, could provide solutions to a wide range of problems facing monitoring authorities struggling to keep up with information-disseminating effect of globalisation. In the context of the issues facing today’s tax administrations, the potential advantages of employing blockchain technology are certainly worth exploring.

Tax administrations today are greatly concerned with distortions produced by a lack of nexus between tax and value-generating activity9exacerbated by the compound effect of globalisation and digitalisation. Most large companies today not only operate cross-border, but also are increasingly moving onto online platforms. At the same time SMEs are becoming more sophisticated and are entering global markets. These trends generate several difficulties for authorities that typically operate nationally within their national jurisdictions, and, more often than not, have little experience of virtual markets. It is becoming

8 Protection, however, is by no means absolute. Hacking presents the greatest threat. 9 OECD/G-20 BEPS, Action 1: Addressing the Tax Challenges of the Digital Economy, Final Reports, Explanatory Statement, p. 16 (Paris: 2015)

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increasingly difficult to assess not only absolute, but also relative tax liability of MNEs. Since the underlying problems are of an international character, they can be dealt only through an international cooperation10, including developing countries, and a common technical platform. Tax authorities (e.g., Estonia, Finland, Rwanda, and the UK) are starting to realise the necessity for increased cross-border cooperation in this area, MNEs are creating sophisticated multiple-step structures that may make it difficult to identify the origins of transactions11. Also, there is an explicit acknowledgement of the importance of the data resource that is becoming available to the regulatory bodies, due to the technological changes. The latter are becoming ‘conscious of responsibility to fully utilise the external data sources available (…) now, and those that will be acquired in the future, through third-party returns, real-time systems, supply chain data and international exchanges’12. Central banks and regulatory authorities such as the BIS are already issuing guidance to clients. This technology is still in its infancy and its potential and true scope of application will only be understood in the next 2-3 years. However, some of the potential uses are already apparent today. Already central banks and financial regulatory authorities such as the BIS are exploring how their can use this new technology. At the same time, the EC and the WCO have established task forces to explore what the risks and potential of this technology are for the roles that they play in the tax and tariffs/ custom duties areas. MNE are also rapidly reviewing how this technology could change their business models. One of the main benefits of the distributed ledger created on the blockchain blueprint is transparency. Crucially, distributed ledgers created using blockchain can also be made “private” to a restricted group of parties, so the data is transparent to them but remains confidential. This is clearly important if the technology is to have wide application in the taxation field, where confidentiality is highly prized. Blockchain could equip the tax authorities with the necessary tools to tackle the problems of global tax compliance, as it provides an unbiased tool essentially designed for uploading and sharing sensitive information between unrelated and untrusting parties. Blockchain technology is capable of enabling a quantum leap for the horizontal coordination and communication between authorities across jurisdictions. Coupled with a secured chain of transaction custody, it might also reduce reliance on the taxpayer user-generated reports, by providing information fed from external independent data sources. Some tax administrations have already introduced distributed ledger technology into their domestic infrastructure. Estonia and Finland are leading examples

10 OECD/G-20 Base Erosion and Profit Shifting (BEPS), Final Reports, Explanatory Statement, p. 5 (Paris: 2015) 11Ibid. 12OECD/Forum on Tax Administration, Advanced Analytics for Better Tax Administration: Putting data to work, 13 May 2016

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within Europe. In May (2016) the Estonian and Finnish Prime Ministers signed the Joint Declaration on an Initial Roadmap for Cross-border Data Exchange and Digital Services between the Republic of Estonia and the Republic of Finland. “We wish to see, by the end of 2016, specific action plans on how and when automatic data exchange will commence between commercial registers, population registers, on social insurance benefits and digital prescriptions,” said the Estonian Prime Minister Taavi Rõivas. “Subsequent agreements concerning tax data, educational qualifications, digital health records and a number of other fields have to be there by end of 2017”13.Currently, Estonia uses distributed ledger technology, developed domestically, known as Keyless Signature Infrastructure (KSI), that enables citizens to access their records stored in governments registers to verify their integrity.

In October 2016, Sheikh Hamdan Bin Mohammed Bin Rashid Al Maktoum, the Crown Prince of Dubai, announced on Twitter Dubai’s goal to become the first government in the world to execute all of its transaction onto a blockchain by 202014. The UK is also well advanced in developing a whole of government approach to Blockchain, including in the area of taxation, and many developing countries are now aware that this technology may enable them to "leap frog" over their counterparts in developed countries, since they have less "legacy" issues from embedded old technology. Critical areas that will benefit from this transition are 1) digitalization of identities, 2) capacity to fight fraud and corruption, 3) health sector and 4) smart cities. Thus, there is a wide-spread recognition within public bodies of the potential benefits of new technologies.

The governments across the globe identify numerous opportunities associated with the transition to blockchain/ distributed ledger technologies. Although the technology is likely to be introduced within a more straightforward context, such as e-voting or e-health, it is expected that ultimately distributed ledgers would be a common foundational technology for more technically sophisticated areas, such as taxation15.

Blockchain: Possible applications to taxation Applications of the blockchain technology make use of either of the two main characteristic of the blockchain technology (removal of the need for intermediary and distributed ledger), or apply it holistically, For example, blockchain applied to payroll or VAT enables removal of a business acting as an intermediary agent collecting taxes on government’s behalf and allows taxes to

13 https://e-estonia.com/e-health-estonian-digital-solutions-for-europe/ 14 http://www.huffingtonpost.com/rahilla-zafar/uae-announces-a-virtual_b_13268928.html 15 In a survey conducted by the World Economic which aimed at estimate the anticipation of the transition or implementation of the new technology by 2025 (the Tipping Points), 73,1% of respondents expect that by 2023, governments will collect tax for the first time via a blockchain. See: Forum World Economic Forum, Deep Shift. Technology Tipping Points and Societal Impact, Global Agenda Council on the Future of Software and Society, Survey Report 2015, p. 7

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be withheld and transferred automatically, using smart contracts. Other applications of the blockchain technology are more focused on the use of distributed ledgers, in particular data recorded therein. Access to data recorded into distributed ledgers, which could be either, public or private, allows for analysis of the data for various uses, in particular with respect to monitoring of compliance, detection of risks of tax evasion, as well as greatly assist in the context of transfer pricing. Some of the possible practical applications, which will be discussed at the March meeting, are briefly considered below.

Tax compliance by design A transparent ledger would provide potential visibility right down to the transactional data. So in principle, the tax administration could view related party transactions in real time and test the accuracy of the pricing model used. As a result, tax administration ‘has the potential to move the function from retroactive analysis and historical financial information gathering to a position where transactions, expenses, assets and liabilities can be re- corded in real time and publicly scrutinized. Mistakes, risk and fraud could, in theory, be eliminated’16.

Payroll The payroll systems in most of the developed economies are fully digitalised. However, payroll tax compliance function is rarely centralised, with ‘multiple regulatory agencies each of which collects duplicate data, holds is centrally, and performs overlapping compliance audits’17. Separate registrars are maintained for the anti-money laundering and KYC purposes. This presents a ‘classic efficiency environment for a distributed ledger’18. Obvious potential of payroll to provide a suitable platform for implementation of blockchain technology, resulted in several solutions being developed, including Futurice (Finland), Bitwage and Quorum. All the solutions, facilitate peer-to-peer transactions, but not yet incorporate participation of the tax administration as regulator. More advanced application of the blockchain technology to payroll will integrate algorithms allowing for removal of an intermediary (employer acting as a government agent, by withholding taxes from the payments to the employees’ earnings), e.g. by embedding smart contracts. The employer then makes the gross payment, plus any employer social security contributions into the system and that would be the end of it for them. Within the system, which would be private (possibly just open to the tax administration and maybe banks) tax data is matched with the payment using smart contract technology to calculate the correct tax and social security due and only the net goes to the employee, whilst government automatically collects the tax. As a result, transaction costs are greatly reduced, as well as opportunity for employers to use payroll taxed to ease their cash-flow problems is removed.

16 Supra n. 3 17Richard T. Ainsworth, Payroll Tax and Blockchain, (To be published), p.20. Article provides a detailed assessment of the use of Blockchain technology for payroll, as well as provides an overview of the existing Blockchain applications for payroll: Futurice (Finland), Bitwage and Quorum. 18Ibid.

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VAT

Currently the VAT system is heavily reliant on business to access and collect the tax due and remit it to government. This involves major risks of non-payment when businesses get into financial trouble, large-scale repayment fraud19 and a high compliance burden for business, particularly SMEs. If transactions were recorded on a distributed ledger and paid through a smart contract that calculated the correct VAT, the tax due could be split from the payment as it is made by the customer and be sent directly to government, resulting in significant reduction of transaction costs and reducing the risk for fraud. Transactions giving rise to a repayment could be verified in real time, thus stymying the sort of carousel fraud we have observed in the past. Such a solution would reduce the need for business to act as an unpaid tax collector and outstanding debt20.

Tax fraud detection/ elimination In the domestic context, distributed ledgers provide comprehensive tax information to allow state regulatory authorities to conduct a compliance audit. A transparent ledger that allows access to financial records in real-time is invaluable in relation to test the accuracy of the pricing model used, especially where the transactions are high risk, say because one of the parties is resident in a tax haven. Going a step further, the distributed ledger could be viewable by the tax administrations of more than one country at the same time, making possible joint assurance activity by tax administrations, subject to the relevant tax treaties. Another example concerns one of the latest tools developed to counteract global tax avoidance and aggressive tax planning: Country by Country (CbC) reporting. Proposed in Action 13 of the OECD/G-20 Base Erosion and Profit Shifting initiative, CbC reporting seeks to provide a summary of the global operations of MNEs, using a standardised template. In the context of fragmented regulatory systems and highly integrated markets, CbC reporting will allow authorities to get a better overview of the businesses operating cross-border. Distributed ledgers could be used to pre-populate the CbC reporting templates in real-time on the basis of transactional data. This would increase the explanatory power of the reports and permit swift reconciliation of the inputs with other outputs, such as audited financial statements, tax returns or statutory reports. Potentially, this could be achieved at lower cost than is involved in producing CbC reports in their current format. More broadly, using blockchain to assure the accuracy of ledgers could play a very important part in bolstering tax control frameworks in MNEs, a key foundation for cooperative compliance relationships.

19 See, for example, Richard T. Ainsworth, Andrew Shact, Blockchain Technology (Distributed Ledger Technology) Solves VAT Fraud, Boston University School of Law, Law & Economics Working Paper No. 16-41 20 PWC has a demo blockchain app “make money smart” for VAT whereas the tax part sends itself to the government automatically with every transaction. Watch http://www.magazine.blockchain.pwc.nl/experience-lab#!/tax

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Transfer Pricing Technology leaders envision a variety of applications for blockchain-based smart contracts, including their relevance to transfer pricing. ‘With a shared database running a blockchain protocol, the smart contracts auto-execute and all parties validate the outcome instantaneously and without need for a third-party intermediary’21. What is the potential of the smart contract with respect to transfer pricing? Blockchain will not replace the current TP principles underlying the transfer pricing rules, but may offer technical solutions for the application of such rules with smart contracts where frequent transactions occur among a network of parties, and manual or duplicative tasks are performed by counterparties for each transaction. The information obtained from the distributed ledgers, which is up-to-date and verified, may be able to serve as an adequate source of data for assessment of pricing models used. Opening up new options for interagency cooperation The post-crisis world has been characterized by a new emphasis on the need for different government departments to cooperate more effectively. This has been particular the case in the area of law enforcement and countering all forms of illicit activities and terrorist financing. Blockchain may open up new possibilities for these different agencies, including the Tax administrations, to share financial information by using a common technical platform. Limitations of blockchain technology Notwithstanding the obvious benefits, blockchain is not a ‘silver bullet’ guaranteed to eliminate all the contentious issues arising from globalisation and mass-digitalisation. It simply represents an evolution of Internet from the ‘Internet of Information’ into an ‘Internet of Value’22. At the moment, the embedded risks are poorly understood, and most likely they relate to the risks that operate in virtual world, such as external hacking, corruption and loss of data. Although encryption provides a solution of superior safety, it is naïve to assume it guarantees an absolute protection of data against cyber-attacks23. Even on a more fundamental level, basic blueprint of the Blockchain technology, which relies on ‘anonymity24 and decentralization’ raises major tax policy and

21John Ream, Yang Chu, and David Schatsky, Upgrading blockchains: Smart contract use cases in industry, Deloitte University Press, 2016. https://www2.deloitte.com/content/dam/Deloitte/nl/Documents/innovatie/deloitte-nl-innovatie-upgrading-blockchains-smart-contract-use-cases-in-industry.pdf 22 Supra n. 4 23Government Office for Science, Distributed Ledger Technology: beyond block chain; A report by the UK Government Chief Scientific Advisor, 2016. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/492972/gs-16-1-distributed-ledger-technology.pdf, p. 6 24 The more accurate term is ‘pseudonym-ity’, as transaction can be traced to the originator, albeit with great difficulties.

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legal questions that will require solutions prior to the practical application of a decentralised ledger systems by tax administrations. Such core issues include the difficulties of answering two fundamental tax questions ‘where’ and ‘who’: lack of nexus to a physical location (therefore identification of the tax jurisdiction) as well as difficulty of establishing the identities of parties to transaction/record25. In the case when neither an identity nor location of taxpayer (or transaction which generated value) can be reliably established, the data gathered in distributed ledgers may be “stateless”, and does not provide tax administration with powers to monitor or enforce compliance. Assuming resolutions of the Blockchain’s identification issues, resulting in anonymity and lack of nexus, which will allow for person-specific financial and tax-related information to be stored in decentralised ledgers, sensitivity of the content raises further issues. Critical concerns address privacy and confidentiality, which have to be balanced with transparency. Also, as information collected by authorities can be used to improve some of the monitoring processes and eliminate tax avoidance, it is also prone to abuse itself. Financial information is highly sensitive, which puts the source of information, in this case a taxpayer, in highly vulnerable position. Therefore, a pre-condition to any increment in the powers of the agencies collecting and using information is a reciprocal equal increment in legal protection granted to the taxpayer. Conclusion To summarise, the interest in blockchain technology is on an unprecedented rise. ‘The demand for openness and transparency, increased connectivity to shared knowledge and information, as well as efficiency and effectiveness, is at a historical high’26. In a world flooded with information but lacking in trust, tools are starting to emerge that allow a systematic assimilation, storage and analysis of data, and trust in the effective use of this invaluable data resource. Such progressive change, when harnessed adequately, has a power to propel many processes rooted in out-dated dogmas to the realities of the modern world. Taxation, both national and international, could significantly benefit from such technological advances. Blockchain technology is likely to become a new foundation for many processes that rely on utilisation of collected information, by producing sets of verified, real-time data. Governments around the globe27 are staring to respond to these technological developments, transferring some of the physically kept ledgers to distributed ledger platforms. Although, due to structural problems, transition to blockchain technology by public sector is not

25 For the critical assessment of the practical possibilities of applying inherently anonymous cyberspace-located Blockchain to tax framework, which, to be enforced must identify and locate the taxpayer, see David Deputy, Is Tax a Stumbling Block for

Blockchain, 9 Sept 2016 (To be published) 26Supra n. 14 2724+ countries are investing in distributed ledger technologies, see World Economic Forum, Deep Shift. Technology Tipping Points and Societal Impact, Global Agenda Council on the Future of Software and Society, Survey Report 2015

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expected to match the speed of consumer markets28 or financial institutions29, the change is clearly underway. From a tax perspective what is essential is that tax administrations are engaged in this debate from the outset to avoid that at some point in the future they are confronted with a technical platform that does not meet their needs and may be difficult to modify. Suggested Materials: o Government Office for Science, Distributed Ledger Technology: beyond block

chain; A report by the UK Government Chief Scientific Advisor, 2016. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/492972/gs-16-1-distributed-ledger-technology.pdf

o World Economic Forum, Deep Shift. Technology Tipping Points and Societal

Impact, Global Agenda Council on the Future of Software and Society, Survey Report 2015

o World Economic Forum, The Future of Financial Infrastructure: An ambitious

look at how blockchain can reshape financial services, An Industry Project of the Financial Services Community, August 2016

o Bank for International Settlements, Distributed Ledger technology in payment,

clearing and settlement, An analytical framework, Committee on Payments and Market Infrastructure, February 2017. http://www.coindesk.com/bis-distributed-ledger-blockchain-report-impact-long-way-off/

o OECD/Forum on Tax Administration, Advanced Analytics for Better Tax

Administration: Putting data to work, 13 May 2016 o IBM, Fast Forward: Rethinking enterprises, ecosystems and economies with

blockchains, IBM Institute for Business Value, June 2016 o McKinsey and Company, How blockchains could change the world, Interview

with Don Tapscott, May 2016, http://www.mckinsey.com/industries/high-tech/our-insights/how-blockchains-could-change-the-world

o Kate Barton, Three Tax Mega Trends to Watch in 2017, Bloomberg BNA, Daily Tax Report (10 DTR J-1, 1/17/17), 2017

28Blockchain-based Israeli start-up La’Zooz is a decentralised, crypto-based alternative to Über, allowing car owners to share rides with each other. http://lazooz.org 29 80% of the banks are predicted to initiate distributed ledger technology-based projects by 2017, supra n 26.

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o David Deputy, Is Tax a Stumbling Block for Blockchain, 9 Sept 2016 (To be

published) o Richard T. Ainsworth, Payroll Tax and Blockchain.(To be published) o Richard T. Ainsworth, Andrew Shact, Blockchain Technology (Distributed

Ledger Technology) Solves VAT Fraud, Boston University School of Law Law& Economics Working Paper No. 16-41

o Ingo Weber, Xiwei Xu, Régis Riveret, Guido Governatori, Alexander

Ponomarev, Jan Mendling, Untrusted Business Monitoring and Execution Using Blockchain, International Conference on Business Process Management, BPM 2016, Business Process Management, pp 329-347

o Joe Stanley-Smith, Blockchain and Tax: What businesses need to know,

International Tax Review, 23 August 2016 o John Ream, Yang Chu, and David Schatsky, Upgrading blockchains: Smart

contract use cases in industry, Deloitte University Press, 2016. https://www2.deloitte.com/content/dam/Deloitte/nl/Documents/innovatie/deloitte-nl-innovatie-upgrading-blockchains-smart-contract-use-cases-in-industry.pdf

o Bloomberg Quick Take: Bitcoin and the Blockchain,

https://www.bloomberg.com/quicktake/bitcoins o Rahilla Zafar, UAE Announces a Virtual Hackathon to Drive Blockchain

Innovation in the Public Sector, http://www.huffingtonpost.com/rahilla-zafar/uae-announces-a-virtual_b_13268928.html

o Z/Yen Group for Long Finance, A Wholesale Insurance Executive’s Guide to

Smart Contracts , Jan 2017 o Don Tapscott, Alex Tapscott “Blockchain Revolution: How the Technology

Behind Bitcoin Is Changing Money, Business, and the World” (Portfolio, May 2016)