Global IFA Congress Award Winners of 2026: Jonathan Seebach & Philipp Riehm
Title of work: From Germany with Love: Comparative Law Thoughts on the 40th Anniversary of Boulez v. Commissioner
The 2026 IFA Congress Award-winning work relates to the Main Subject of the 2026 IFA Congress in Melbourne: Taxation of Royalties for the Use of, and Gains from the Sale of, Intellectual Property/Intangibles.
Short description: The winning article analyses the 1984 Boulez v. Commissioner case, addressing the distinction between royalty and service income in a German-American cross-border context from a German comparative law perspective. As a result of the analysis, the authors suggest legislative solutions that interact with the role of internal intellectual property law in attributing income sources. The article highlights the need to look beyond tax law and address how underlying intellectual property law can create and resolve international double taxation.
To discover the scientific programme of the Congress and register, please visit the IFA 2026 Melbourne Congress website.
Mitchell B. Carroll Award Winner of 2026: Vincent Doix
Title of work: Customs Duties and Indirect Taxation
Short description: The winning work analyses the fiscal nature of customs duties and their legal regime. It highlights the divergence between the legal frameworks governing customs duties and taxes, leading to incoherence in areas such as customs valuation and transfer pricing. The author argues that customs duties have progressively become detached from tax policy, contributing to the current lack of policy coherence. To address these challenges, the work proposes greater harmonisation of legal regimes and closer alignment between fiscal and customs policies.
To find information on IFA Research and Awards, please visit this page.
Poster Programme Winners of 2026
At the occasion of the 2026 Congress in Melbourne, the following participants were selected for the Poster Programme:
PhD:
- Annas Akbar Sultansyah (Indonesia/Australia): "Carbon Taxing rights in Coal-Exporting Economy"
- Dominic Thierstein (Switzerland/Austria): "Substantive Scope of the Model Conventions (Income and Capital vs Estates, Inheritances and Gifts)"
- Doris Canen (Brazil): "Intellectual Property Cross Border Remittances: Nexus and Substance Treaty Challenges"
- Gangshan Cao (China/Austria): "Capital’s Role in Transfer Pricing under the Arm’s Length Principle"
- Katarzyna Smoleń (Poland): "The evolution of mechanisms countering Base Erosion and Profit Shifting (BEPS), with a focus on the Global Minimum Tax (Pillar II)"
- Kilian Posch (Austria): "The Carbon Border Adjustment Mechanism of the EU: Analysis in the Light of EU Competence Law, WTO Law and International Tax Law"
- Rhodah N.K. Nyamongo (Kenya/Austria): "Rethinking the Nexus Rules in the Age of Artificial Intelligence-Driven Business Models: Limitations in Traditional Doctrinal Concepts and Pathways for Reform"
- Tiina Ruohola (Finland): "Outside of Scope Activities and Their Effect on Input VAT Deduction Rights"
- Tsireledzo Ambani Mulaudzi (South Africa): "The Taxation of Income Received by South African Residents Operating in the Digital Economy"
- Wide Metrika Putra (Indonesia/Australia): "Cooperative Compliance: Stakeholders Perspective and Contextual Adaptation for Indonesia’s Tax System"
LLM:
- Lorenzo Agati (Italy /Netherlands): "Reconstructing Comparability of Investment Funds under EU Law"
- Lucas Tarbouriech (France /Austria): "Expanding source state taxing rights through Articles 12A and 12AA: the United Nations Model Convention's response to the limits of transfer pricing rules in the digital economy"