Developments on tax subjectivy. The case for artificial intelligence. Sviluppi in tema di soggettività tributaria. Il caso dell'intelligenza artificiale

Considerable similarities can be envisaged between civil and tax studies on the subjectivity, despite the different relationships and interests regulated. In tax matters, subjectivity can be conceived as a regulatory technique, functional to the determination of the subject matter which justifies the contribution of the taxpayers to public expenses. Taxable persons, however, must be distinguished from taxpayers: the former reflect the technical nature of tax law; the latter, its social and constitutional dimension. In this view, artificial intelligence cannot be regarded as a taxpayer itself, but the object of a tax that necessarily concerns its user.