TAXATION OF DIGITAL HUMANS AND AI – GENERATED WORK: RETHINKING FISCAL LIABLITY IN THE AGE OF AUTONOMOUS INTELLIGENCE
AUTHOR – DEEPA .G, LLM (TAXATION LAW) POST GRADUATE STUDENT IN SCHOOL OF EXCELLENCE IN LAW, TAMIL NADU DR. AMBEDKAR LAW UNIVERSITY, THARAMANI CHENNAI 113.
BEST CITATION – DEEPA .G, TAXATION OF DIGITAL HUMANS AND AI – GENERATED WORK: RETHINKING FISCAL LIABLITY IN THE AGE OF AUTONOMOUS INTELLIGENCE, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 5 (13) OF 2025, PG. 61-75, APIS – 3920 – 0001 & ISSN – 2583-2344.
ABSTRACT
The fast growth of artificial intelligence has given rise to digital humans, virtual influencers, and autonomous AI systems that can generate significant income through creative, commercial, and algorithmic activities. This new development challenges the basic principles of current tax laws, which focus on human authorship, residence, and identifiable income sources. This study aims to explore how tax laws can change to keep pace with this digital landscape, where non-human entities can generate and earn revenue independently. It looks into the main question of who should be taxed for AI-generated work. Should it be the developer, the user, the platform, or the AI itself? The study also addresses the complexities of jurisdiction, valuation challenges, and income classification in international AI operations. By examining international approaches such as the OECD’s digital economy initiatives and the European Union’s proposals, the research aims to identify gaps in policy and suggest a framework for India and other regions. Ultimately, this paper emphasizes the urgent need to redefine taxable personhood, income classification, and liability in the age of artificial intelligence to promote fairness, responsibility, and legal certainty in global tax systems.
KEYWORDS: artificial intelligence taxation, digital humans and virtual influencers, AI-generated income, taxable personhood, jurisdiction and source of income, international tax frameworks, OECD digital economy model, and legal reform for AI-driven work.