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About
Eduardo Baistrocchi is Associate Professor of International Tax Law at the London School of Economics and Political Science. He studied law at the Universidad de Buenos Aires, the LSE and Harvard Law School. He has been a Distinguished Visiting Professor at FGV Direito São Paulo, Northwestern University and the University of Toronto, and has held Chevening and Fulbright Scholarships.
His research focuses on international and corporate taxation. He has published in leading journals and with leading publishing houses, including the British Tax Review, Florida Tax Review, Global Tax Treaty Commentaries, the Modern Law Review, The Tax Lawyer, the Virginia Tax Review, the Oxford Journal of Legal Studies and Cambridge University Press.
Professor Baistrocchi is a frequent speaker on international tax issues and has presented his research at global and regional conferences, including the Academic Symposium of the Oxford University Centre for Business Taxation, the Vienna University of Economics and Business Transfer Pricing Symposium and the Global Tax Symposia.
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. His forthcoming book, The Making of International Taxation: Between Globalisation and Deglobalisation (under consideration for publication by Oxford University Press), explores the driving forces behind the emergence and evolution of the international tax regime over its first century (1923–2025) and advances a proposal for re-imagining global tax governance.
Research
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 treatiseA Global Analysis of Tax Treaty Disputes(London: Cambridge University Press, 2017).
Publications
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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click here for video presentations from LSE book launch of A Global Analysis of Tax Treaty Disputes
Reviews:
Matthieu Possoz, Revue de droit international et de droit comparé, 2019, n° 2, pp 329-330 (Belgium)
Professor Frans Vanistendael, INTERTAX, 2019, Volume 47, Issue 4, pp 416-417
Daniel Gutmann, Revue de Droit Fiscal, N° 46, 16 November 2017, p. 12 (France)
John Avery Jones, British Tax Review, N° 5, December 2017, pp. 669-671 (United Kingdom)
Haiyan Xu, Beijing Law Review, N° 9, May 2018, pp. 132-136 (People´s Republic of China)
Kim Brooks, Canadian Tax Journal, 2018, 66:2, pp. 507-508 (Canada)
Craig Elliffe, Australian Tax Review, 2018, Volume 47, N° 2 pp. 160-161 (Australia)
Tsilly Dagan, Modern Law Review, 2018, Volume 81, N°4, pp 730-733 (United Kingdom)
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]
- 'Article 9: Associated Enterprises - Global Tax Treaty Commentaries' Global Topics IBFD (published Mar. 2025)
- 'Global Tax Hubs' Florida Tax Review (December 2024) 27 (2) 43 pages
- 'UK Tax Treaty Policy and Practice' Global Tax Treaty Commentaries (2024) IBFD, The Netherlands, 75 pages
- 'Article 9: Associated Enterprises - Global Tax Treaty Commentaries' Global Topics IBFD, December 2023, The Netherlands
- 'International Taxation, the G-7, and India: A Proposal', Tax Notes International, October 30, 2023, p. 653, available at SSRN
- United Kingdom Policy and Practice (December 6, 2022). Global Tax Treaty Commentaries, IBFD, The Netherlands., Available at SSRN: https://ssrn.com/abstract=4298369
- Article 9: Associated Enterprises - Global Tax Treaty Commentaries (December 20, 2022). Global Tax Treaty Commentaries, IBFD, the Netherlands., Available at SSRN: http://ssrn.com/abstract=4321666
- 'Article 9: Associated Enterprises — Global Tax Treaty Commentaries'Global Tax Treaty Commentaries, International Bureau of Fiscal Documentation, 2022
- 'Global Tax Treaty Commentaries, Country Policy & Practice: United Kingdom' International Bureau of Fiscal Documentation, pp.1 – 54, 2021
- 'The International Tax Regime and Global Power Shifts' (Winter 2021). Virginia Tax Review, Vol. 40, No. 02
- 'The Future of Transfer Pricing, Report on Argentina (1932-2017)' (August 29, 2017). Cahiers de Droit Fiscal International, Volume 102 B: The Future of Transfer Pricing, 91-110, International Fiscal Association,
2017 Rio de Janeiro Congress. - 'Article 9: Associated Enterprises — Global Tax Treaty Commentaries' (August 29, 2017). Global Tax Treaty Commentaries, International Bureau of Fiscal Documentation, 2017
- 'Tax Treaty Dispute Resolution: The Global Evolutionary Path' in E. Baistrocchi (ed), A Global Analysis of Tax Treaty Disputes (Cambridge University Press, 2017)
- 'Patterns of Tax Treaty Disputes: A Global Taxonomy ' in E. Baistrocchi (ed), A Global Analysis of Tax Treaty Disputes(Cambridge University Press, 2017)
- 'Tax Treaty Disputes: A Global Quantitative Analysis´ in E. Baistrocchi (ed), A Global Analysis of Tax Treaty Disputes (Cambridge University Press, 2017) (with Martin Hearson)
- 'The International Tax Regime and the BRIC World: Elements for a Theory'Oxford Journal of Legal Studies, 2013
- 'Transfer Pricing Dispute Resolution: The Global Evolutionary Path (1799–2011)' in Eduardo A Baistrocchi and Ian Roxan (eds), Resolving Transfer Pricing Disputes: A Global Analysis (Cambridge University Press 2012)
- 'Tax Disputes under Institutional Instability: Theory and Implications' Modern Law Review (2012), Volume 75, Issue 4, 547-577
- 'The Use and Interpretation of Tax Treaties in the Emerging World: Theory and Implications' (September 24, 2008). British Tax Review, No. 4, 2008
- 'The Transfer Pricing Problem: A Global Proposal for Simplification' (Summer 2006). Tax Lawyer, Summer 2006
- 'The Arm's Length Standard in the 21st Century: A Proposal for Both Developed and Developing Countries'Tax Notes International, pp. 241-255, October 18, 2004