Mr Eduardo Baistrocchi

Mr Eduardo Baistrocchi

Associate Professor of Law

Department of Law

Telephone
020-7955-6395
Room No
New Academic Building 7.33

About me

Eduardo Baistrocchi is Associate Professor of Law at the London School of Economics and Political Science. He studied law at the Universidad de Buenos Aires before obtaining an LLM at Harvard Law School and later an LLM on Tax Law at LSE. He has been a Fulbright Scholar and a Chevening Scholar. He has also been a Distinguished Visiting Professor in Brazil (FGV Direito Sao Paulo), Canada (University of Toronto) and the United States (Northwestern University). His research and publications are focused on international taxation, with a particular emphasis on tax treaty disputes in the G20. He applies interdisciplinary approaches, such as game theory and public choice, to investigate how the international tax regime operates. He has published in leading journals and publishing houses such as the British Tax Review, Global Tax Treaty Commentaries, the Modern Law Review, the Oxford Journal of Legal Studies (OJLS) and Cambridge University Press. His OJLS piece has been considered one of the most important papers published in the last two decades on all continents. He is the principal author and editor of the first treatise offering a global analysis of tax treaty disputes in the G20 and beyond within the first century of international taxation.

Research interests

His current research focuses on developing a theory on the international tax regime in the G20 since its emergence in the early 20th century. This theory aims to be grounded on data collected for the preparation of the treatise A Global Analysis of Tax Treaty Disputes (London: Cambridge University Press, 2017)

Teaching

Books

A Global Analysis of Tax Treaty Disputes (ed.) (London: Cambridge University Press, 2017)

This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach, the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.

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Resolving Transfer Pricing Disputes: A Global Analysis (ed. with Ian Roxan) (London: Cambridge University Press. 2012)

 Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.

click here for publisher's site

reviewed in British Tax Review  
[this review was first published by Thomson Reuters (Professional) UK Limited in British Tax Review (2013) Vol.58 British Tax Review, Issue 5 and is reproduced by agreement with the Publishers]

reviewed in Tax Notes International


 

Transfer Pricing Litigation: Theory and Practice, Lexis Nexis, 2008

Articles