Evelyse Carvalho Ribas

Profile

Dr Evelyse Carvalho Ribas is a legal scholar and international practitioner whose work sits at the intersection of tax, regulatory and international law. Her doctoral research at the University of Leeds produced the first comprehensive legal analysis of why cross-border cultural-creative tax incentives systematically fail to deliver the access they promise – and of how that failure can be diagnosed and reformed. Admitted to practise in Brazil, Portugal and England & Wales, she brings more than twenty years of international practice to her scholarship, across two domains that share a single structural problem: fragmentation and institutional misalignment at the intersection of national, bilateral, EU and international legal orders.

Her thesis, Toward a Coordinate Framework for Cultural-Creative Tax Incentives (supervised by Peter Whelan, Federica Casano and Or Brook), makes an original doctrinal contribution through two frameworks now in active advisory use: Structural Fiscal Access Constraints (SFACs) and the Cultural-Creative Tax Incentive Model (CCTIM). Together they move the field from describing exclusion to diagnosing and remedying it – reframing cultural-creative tax incentives as shared transnational legal objects whose effectiveness depends on the alignment of rights, procedures and institutions.

At the centre of the thesis is the identification and theorisation of Structural Fiscal Access Constraints (SFACs): systemic barriers embedded in the legal, administrative and institutional design of incentive regimes that prevent legitimate access. SFACs are shown to crystallise across three interdependent layers – normative (legal), administrative and institutional – producing a persistent gap between rights that are textually affirmed and rights that are functionally accessible.

The analysis is conducted through five analytical variables – legal certainty, rights-based enforcement, conditioned sovereignty, functional integration and mutual supportiveness – applied to three instrument categories (tax-in-lieu for visual artists, cultural-philanthropy deductions and audiovisual production tax credits) across national, bilateral, EU and UNESCO frameworks, and across jurisdictions including the EU Member States, the UK, US, Canada, Australia, Brazil, Chile and Mexico.

In response, the thesis develops the Cultural-Creative Tax Incentive Model (CCTIM) – a soft-governance architecture, anchored in the normative ecosystem of the UNESCO 2005 Convention and compatible with EU proportionality, non-discrimination and free-movement principles, that reduces access barriers through shared definitions, equivalency principles, procedural safeguards and cross-jurisdictional interpretive tools, without requiring doctrinal harmonisation or the surrender of fiscal sovereignty. The wider paradigm it advances – Cultural-Transnational Legalism – measures cultural cooperation not by the number of commitments undertaken, but by their accessibility, predictability and enforceability across legal systems.

Dr Carvalho Ribas’s frameworks are applied beyond the academy. She advises national supervisory authorities, regulators and institutions on identifying the legal and administrative blind spots that block access to tax incentives, and on aligning domestic regimes with bilateral, EU, OECD, and UNESCO obligations. Active in the digital-asset field since 2015, she applies a Multi-Layer Governance Framework (MLGF) – spanning legal-normative, institutional-administrative, governance-decision, economic-value, technical-functional and jurisdictional dimensions – to tokenisation across real estate, film, agriculture, intellectual property, eco-assets and education.

She translates this research into professional education for lawyers, tax advisers, regulators and policymakers through MoroAK, a professional knowledge-infrastructure platform. She is a member of the Global Digital Finance (GDF) Tax Working Group, and has served as Rapporteur to the Brazilian Bar Association Ethics Court and as a volunteer conciliator and mediator in the Brazilian civil and criminal courts.

Research interests

• The design and governance of tax incentives – cultural-creative, R&D, audiovisual, philanthropy, intellectual property, energy, carbon, agriculture and infrastructure – where structural access barriers arise

• Fiscal governance across national, bilateral, EU, UNESCO, and OECD legal orders, and the procedural realisation of rights

• Soft-governance mechanisms, equivalency and institutional coordination in transnational legal systems

• Digital assets, tokenisation and multi-layer regulatory governance (MiCA, MiFID II, FSMA 2023, CVM 50/21; FATF, FATCA, CRS, GDPR)

• Carvalho Ribas, E. (2026) Toward a Coordinate Framework for Cultural-Creative Tax Incentives. PhD thesis, University of Leeds (White Rose eTheses).

• Carvalho Ribas, E. (2026) TxI-01 – Cultural and Creative Tax Incentives: A Cross-Border Legal and Regulatory Framework. MoroAK working paper.

• Carvalho Ribas, E. (2026) DA-01 – Blockchain, Web3 and Digital Assets: Legal Ontology, Governance Complexity and the Limits of Analogical Regulation. MoroAK working paper.

• Carvalho Ribas, E. (2010) Tax Avoidance: Limits of Legality in Brazil and the United Kingdom. LAP Lambert Academic Publishing. ISBN 978-3838383064.

• Carvalho Ribas, E. (2023) Artists on the Move: Revealing the Hidden Barriers in Tax Incentives. Art Law.

Full publication record: ORCID 0000-0003-2744-5977 · SSRN Author ID 10488356.

Qualifications

• PhD Law — Uni of Leeds, 2026. Toward a Coordinate Framework for Cultural-Creative Tax Incentives
• LLM, Intl Com Law — Uni East Anglia, 2007. Tax Avoidance — Limits of Legality Legal Systems BRA/UK
• International Law — PUC, Bra, 2005. Heteronomous Tax Exemptions and International Treaties
• LLB Law — Uni Contestado, Bra, 2004. Lex Mercatoria in International Contracts