International Automation Rent and Destination Equalisation Accord: A Treaty Working Draft with an Optional Robotic Public and Consumer Safety Protocol

Abstract

Advanced automation can increase productive output and economic rent while weakening the historic connection between production, labour income, household demand and the domestic tax base. This working paper develops an institutional response for the post-post-automation economy through two separately adoptable instruments. Part I proposes the International Automation Rent and Destination Equalisation Accord (IARDEA). Rather than treating relocation as the taxable event or imposing a conventional border tariff, the framework establishes an enterprise-level Destination Equalisation Tax (DET). A 24 per cent ordinary company-tax benchmark is combined, as an explicit calibration parameter, with a 16 per cent excess-rent layer. Excess rent is identified at consolidated-group level before destination allocation, reducing the ability of internal royalties, intellectual-property migration and related-party financing to relocate the rent through accounting form alone. Equivalent foreign taxes are credited to prevent double collection. The framework adds an Essential Import Consumer-Incidence Cap (ECIC), deferred equalisation balances, distributor anti-squeeze safeguards, commercial-substance safe harbours, structured rebuttal and document-request procedures, constituent-State compliance rules for economic blocs, mutual recognition, information exchange, and non-retaliatory dispute settlement. Part II develops a separately adoptable Robotic Public and Consumer Safety Protocol for the continuing obligations created by autonomous productive capital. It covers continuing safety warranties, Robot-as-a-Service maintenance and replacement, accountable human oversight, foreseeable public interference, incident response, software-version responsibility, secure staged updates, event-record preservation, multi-robot incidents, end-of-support duties, no safety-by-subscription, and financial continuity where a provider fails. The paper includes preliminary EU/WTO and international-tax compatibility analysis, a Group Adjusted Capital schedule, Pillar Two interaction rules, ECIC and distributor worked examples, and synthetic stress tests examining intellectual-property migration and avoidance pathways. The central proposition is that a post-automation settlement requires more than replacing lost household income. It also requires mechanisms for maintaining the public claim on highly automated productive capacity, protecting economic circulation from incidence shocks, and assigning continuing responsibilities to autonomous capital operating within human environments. Supplementary Annex A — Post-Publication Validation Notes (6 September 2026). A companion annex has subsequently been added to this record to document design questions, proposed refinements and validation tasks arising from post-publication critique. It does not amend or replace the published v0.3 working paper. The annex addresses origin-neutral treatment of non-Party foreign-tax credits; cross-sector incidence of the cost-basis Group Adjusted Capital (KGK_G) rule; proposed Controlled Group and de minimis thresholds; a proposed statutory Safe Service Life floor for robotic systems; Tier 2 multi-provider compensation backstops; coalition and entry-into-force fragmentation risks; revised interpretation of the first synthetic pilot; and legal and technical reference verification. These items are retained as prospective material for later validation and any future consolidated instrument. Two-Page Policy Brief — 6 September 2026. A concise policy brief has also been added to this record for readers who want the institutional architecture without the full treaty drafting. It summarises the economic problem, the IARDEA/DET mechanism, consumer-incidence protections, the optional Robotic Public and Consumer Safety Protocol, and the principal legal, empirical and institutional steps required for further development.