IFA President YIN Scientific Award

Winner 2021
Gaetano Manzi (Italy) - The Autonomous Interpretation of the Multilateral Instrument with Particular Relevance to Article 2(2)

The IFA President YIN Scientific Award was launched in 2014. This Award shall be awarded for an article published in a qualified medium, furthering the understanding of international fiscal law or comparative tax law, providing practical solutions to problems arising in cross-border transactions or situations.

Subject: Any topic furthering the understanding of international fiscal law or comparative tax law, providing practical solutions to problems arising in cross-border transactions or situations.
Language: English.
Open to: Young IFA Network (YIN) members under 35 years of age on the 31 of July of the year in which the Prize is awarded.
Prize: Euro 1.000, plus a memento, a certificate and an invitation to attend the IFA 2020 Congress in Cancun, exempted from the payment of the Congress registration fee, during which the Prize is awarded. Due to the Covid-19 situation the 2020 Cancun Congress had to be postponed to 2022. At this moment the IFA Board is working on a solution to give the 2020 winner of the IFA President YIN Scientific Award suitable exposure.
Submission deadline: 1 April 2021, by e-mail.

Please contact the IFA General Secretariat for further details at [email protected].

Previous winners of the Award

 

2021

Winner Gaetano Manzi - Italy The Autonomous Interpretation of the Multilateral Instrument with Particular Relevance to Article 2(2)

2020

Winner Giorgio Beretta - Italy Citizenship and Tax

2019

Winner Hannelore Niesten – Belgium Revisiting the Fiscal and Social Security Status of Highly Mobile Workers in the Road and Railway Transportation: Quo Vadis?

2018

Winner Félix Daniel Martínez Laguna - Spain Abuse and Aggressive Tax Planning: Between OECD and EU Initiatives. The Dividing Line between Intended and Unintended Double Non-Taxation

2017

Winner Dhruv Sanghavi - India The Proposed Tiebreaker Rule in OECD/G20 BEPS Action 6: A Critical Examination of the Possible Motives and Means, and a Potential Alternative
  Honourable mentions Nathalie Bravo - Venezuela
Stefano Marini - Hong Kong
The Multilateral Tax Instrument and Its Relationship with Tax Treaties
On the Source and Taxation of Royalties in Hong Kong

2016

Winner Blazej Kuzniacki - Poland The Need to Avoid Double Economic Taxation Triggered by CFC Rules under Tax Treaties, and the Way to Achieve it
  Honourable mention Lucas Carvalho - Brazil Chapter 5 The OECD Plan to Neutralise the BEPS Effects of Hybrid Mismatch Arrangements: Challenges Ahead?

2015

Winner Kasper Dziurdz - Poland Attribution of Functions and Profits to a Dependent Agent PE: Different Arm's Length Principles under Articles 7(2) and 9?
  Honourable mention Christoph Marchgraber - Austria The Avoidance of Double Non-taxation in Double Tax Treaty Law: A Critical Analysis of the Subject-To-Tax clause Recommended by the European Commission

2014

Winner Dirk Maarten Broekhuijsen - Netherlands A modern understanding of Article 31(3)(c) of the Vienna Convention (1969): A new haunt for the commentaries of the OECD Model

  Honourable mention Blazej Kuzniacki The Service PE Concept in light of the Poland-Norway Income Tax Treaty (2009)

 

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