Yariv Brauner. Cécile Brokelind

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Yariv Brauner Yariv Brauner is a Professor of Law with the Levin College of Law, University of Florida. He joined the Florida faculty in 2006, after teaching at NYU, Northwestern and ASU.

He is an author of several articles published in professional journals and law reviews, and a co-author of U.S. International Taxation Cases and Materials (with Reuven S. Avi-Yonah and Diane M.

1 Yariv Brauner Yariv Brauner is a Professor of Law with the Levin College of Law, University of Florida. He joined the Florida faculty in 2006, after teaching at NYU, Northwestern and ASU. He has been a Visiting Professor or a guest speaker in various universities in the U.S. and abroad. He is an author of several articles published in professional journals and law reviews, and a co-author of U.S. International Taxation Cases and Materials (with Reuven S. Avi-Yonah and Diane M. Ring), now in its 3 rd. ed. He taught multiple courses in the fields of Taxation, Corporate Taxation, International Taxation, International Trade Law, and the Law of Multinational Corporations. Education: LL.B., 1996, Hebrew University School of Law, LL.M. in International Taxation, 1998, J.S.D, 2003, New York University School of Law. Cécile Brokelind Cécile Brokelind, associate professor, Department of Business Law, School of Economics and Management, Lund University, Sweden, is one of the founding members of the GREIT network. She is currently involved in several research projects on human rights and taxation, tax law assessment, ex post, tax incentives and State Aid rules, principles of EU tax law, and manages - and teaches- the one year Masters of European and International Tax Law. She has written extensively on EU tax law and group taxation, and focuses on integrating research in education on a daily basis.

Vikram Chand Vikram Chand, University of Lausanne: started his career in a consulting firm wherein he advised high net worth individuals, multinationals and domestic companies on structuring

From 2010, he has been the academic coordinator of the MAS in International Taxation Program in Switzerland wherein he coordinates the program and lectures regularly on different international tax

2 Vikram Chand Vikram Chand, University of Lausanne: started his career in a consulting firm wherein he advised high net worth individuals, multinationals and domestic companies on structuring cross-border transactions, devising transfer pricing strategies, conceptualizing business restructurings and making representations before tax authorities. From 2010, he has been the academic coordinator of the MAS in International Taxation Program in Switzerland wherein he coordinates the program and lectures regularly on different international tax topics related to tax treaties, EU tax law, transfer pricing, international tax planning and comparative taxation. Additionally, he speaks at several universities, conferences, consulting firms and is undertaking a doctorate in international tax law which focuses on the interaction of domestic anti abuse measures with tax treaties. Tsilly Dagan Tsilly Dagan (LL.B; JSD, Tel Aviv University; LL.M (in Taxation) NYU) is a Professor of Law at Bar-Ilan University, Israel. She was a visiting assistant professor at the University of Michigan and at the University of Western Ontario, a Scholar in Residence at Columbia Law School and a member of the Group on Global Justice at the Institute of Advanced Studies, Jerusalem. Her book, International Tax Policy: Between Competition and Cooperation is forthcoming at Cambridge University Press, Professor Dagan is the author of numerous articles including Rights for Sale, 96 Minnesota Law Review 90 (2011) (with Talia

3 Fisher); Commuting, 26 Virginia Tax Review 185 (2006); and The Tax Treaties Myth, 32 NYU Journal of International Law and Politics 939 (2000). Luc De Broe Born 1959, graduated from the Katholieke Universiteit Leuven (lic.jur., K.U.Leuven, 1982). He obtained a Master of Laws (LLM) degree from the Northwestern University School of Law (Chicago, 1986). He obtained a degree in tax law from the Ecole Supérieure des Sciences Fiscales Bruxelles (1987) and obtained his doctorate degree at Katholieke Universiteit Leuven on the dissertation International tax planning & prevention of abuse under domestic tax law, tax treaties & EC-law. Since 2007, Luc De Broe is a member of the executive committee of the IFA. He is the author of numerous articles on Belgian, international and European tax law; of a manual on cross-border leasing between Belgium and the United States (for which he was awarded the Mitchell B. Carroll Prize of IFA, 1988); a manual on mergers and divisions of Belgian enterprises (1993) and a dissertation on International tax planning & prevention of abuse under domestic tax law, tax treaties & EC-law.

She is a founding member of Group for Research on European and International Taxation (GREIT).

4 Ana Paula Dourado Professor of Tax Law and International and European Tax Law at the University of Lisbon. She has been a visiting Professor at several European universities, at the University of Florida and at the MoF in Taiwan. She is a founding member of Group for Research on European and International Taxation (GREIT). She has drafted and negotiated the tax reforms in Portuguese speaking countries as an expert at the legal department of the International Monetary Fund. She was a Member of the Centre for Tax Studies at the Portuguese Ministry of Finance and a delegate for Portugal in the working groups for direct tax harmonization at the European Community and in the working group for tax avoidance and evasion at the OECD. She is a board member at Intertax, Revista de Finanças Públicas e Direito Fiscal, and regular collaborator in other journals. Member of the EATLP Academic Committee ( ) and the Executive Board ( ). Member of the European Commission Platform for Tax Good Governance. Roland Ismer Roland Ismer (born in 1974) studied law and economics at the universities of Constance, Geneva, and Munich and at the London School of Economics, UK. After completing his legal training in Munich and a doctoral degree on tax law, he worked for a large US law firm as a lawyer and, from 2006, a tax advisor. From 2006 to 2009, he was a research fellow at LMU Munich, where he completed his habilitation on Combating climate change as a legal problem in Professor Ismer has been Chair of Taxation and Public Law since His main research topics are German and international

5 tax law, legal issues relating to climate change, and the economic analysis of public law. Błażej Kuźniacki Ph.D in law (University of Oslo), master of law and master of European studies (summa cum laude) at the University of Nicolaus Copernicus in Torun, Research Fellow at the Singapore Management University Tax Academy Centre for Excellence in Taxation. Of Counsel at the PATH Augustyniak, Hatylak & Partners LLP, Associate at the Centre of Tax Documentation and Studies and the Foundation Centre of Tax Documentation and Studies in Lodz. Member of Polish and Norwegian Branch of International Fiscal Association, Member and co-founder of Association of PhD Students and Doctors of Tax Law, founder of the blazejkuzniacki.pl blog and laureate of a prestigious 2015 Scholarship of Foundation for Polish Science and 2016 IFA President YIN Scientific Award. The author of more than 60 articles/book chapters which primarily focus on international, European and comparative aspects of income taxation. Speaker at Polish and foreign conferences and seminars, guest lecturer at Polish and foreign universities.

Richard Lyal Richard Lyal is a member of the Legal Service of the European Commission and was responsible for direct taxation in that service for a number of years.

taxation (both direct and indirect). Author (with Paul Farmer) of EC Tax Law, OUP 1994.

6 Richard Lyal Richard Lyal is a member of the Legal Service of the European Commission and was responsible for direct taxation in that service for a number of years. He has been agent for the Commission in more than 350 cases before the EU courts, the EFTA Court and the European Court of Human Rights, mainly in the fields of competition, State aid and taxation (both direct and indirect). Author (with Paul Farmer) of EC Tax Law, OUP Sophia Piotrowski Sophia Piotrowski is a research associate and PhD student at the University of Erlangen-Nuremberg (FAU). She holds degrees in Law and Business Law from the University of Erlangen-Nuremberg. Her research focuses on European state aid law. She is an author in the upcoming German edition of the Vogel& Lehner Commentary on DTCs

7 Pasquale Pistone Prof. Pasquale Pistone is the Academic Chairman of IBFD. He holds a Jean Monnet ad personam Chair in European Tax Law and Policy at WU Vienna University of Economics and Business (Austria) and is Associate Professor of Tax Law at the University of Salerno (Italy). His main fields of expertise are European and international tax law, in which he is regarded as a top academic expert in various parts of the world. Over the past 15 years he has lectured extensively on issues of European and international tax law (at several universities in 12 EU countries, 3 further European countries and 13 non-european countries) and has reported at over 150 specialized tax conferences around the world. He has been invited to present his views in meetings organized by the European Commission, the European Court of Justice and the OECD. Prof. Pistone has been visiting professor of European and/or International Tax Law at various universities, including Florida, Lisbon, Louvain UCL, Melbourne (UM and Monash), Paris (I and II) and Sao Paulo. In his IBFD capacity he is a member of the Executive Board of the EATLP (European Association of Tax Law Professors) and of the Permanent Scientific Committee of the IFA (International Fiscal Association). Prof. Pistone is the editor-in-chief of the World Tax Journal (IBFD), a fully peer-reviewed interdisciplinary international tax journal. He is also a member of the board of editors of Diritto e Pratica Tributaria Internazionale (Cedam, Italy) and of the scientific board of several other specialized tax journals in Europe, Russia and South America. He has participated in and directed several research projects. He was a founding member of the GREIT (Group for Research on European International Tax Law), of ILADT s research project on a Model Tax Convention for Latin-America, of WU Vienna s research project on International Tax Coordination (funded by the Austrian Science Fund) and of the DeSTaT project on global fiscal transparency and developing countries (funded by the Norwegian Research Council). He is also Executive editor of IBFD s Global Tax Treaty Commentary project. Prof. Pistone is a member of the ECJ Task Force of the Confédération Fiscale Européenne (since 2008), honorary member of the Instituto Uruguayo de Estudios Tributarios (since

2007) and of the Malta Institute of Management (since 2011) and member of the Advisory Board for the Foundation for International Taxation (FIT) (since 2016).

8 2007) and of the Malta Institute of Management (since 2011) and member of the Advisory Board for the Foundation for International Taxation (FIT) (since 2016). Among other prizes and distinctions, he was presented with the EURYI Award of the ERF (European Science Foundation) in Prof. Pistone works in seven European languages (Italian, English, French, German, Spanish, Portuguese and Dutch). He has published extensively on international and European tax law as (co-)editor of 34 books and author of two books and over 160 articles translated in ten languages around the world. Luís Eduardo Schoueri Luis Eduardo Schoueri is a full professor of tax law at the University of São Paulo Law School, the vice-president of the Brazilian Institute of Tax Law (IBDT) and a founding partner at Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados. He obtained a master s degree in Law from the University of Munich, and completed doctor s and free professor s degrees at the University of São Paulo. Since 2013, he has been a professor at the Tax Law Summer School (Pontifícia Universidade Católica Portuguesa, Portugal); GREIT Lisbon Summer Course on European Tax Law (University of Lisbon, Portugal); LLM in International Tax Law, Amsterdam Centre for Tax Law (University of Amsterdam, The Netherlands); and LLM in International Tax Law (Vienna University of Economics and Business, Austria). Prof. Schoueri has also lectured as a visiting professor at the Université Catholique de Louvain, Belgium (2012), Université Paris 1 Pantheon-Sorbonne, France ( ) and University of Florida, United States (2007). He was the Hauser Global Professor of Law for the 2016 spring semester at New York University (NYU). For , he is Professor in Residence at IBFD. Besides several articles published in Brazil and abroad, Prof. Schoueri has authored various books on tax law, including Direito Tributário (Tax Law, 6th ed., 2016); Preços de Transferência no Direito Tributário Brasileiro (Transfer Pricing in Brazilian Tax Law, 3rd ed., 2013); Ágio em Reorganizações Societárias (Goodwill in corporate reorganizations, 2012); and Normas Tributárias Indutoras e Intervenção Econômica (Tax norms with inducing effect and economic intervention, 2005).

D P Sengupta DP Sengupta joined the Indian Revenue Service in the year 1975 and retired as Chief Commissioner of Income-Tax (Central), Delhi after gaining 33 years of work experience.

He was also the Competent Authority for India. He continues to have association with matters relating to direct taxation, particularly in the area of international taxation.

9 D P Sengupta DP Sengupta joined the Indian Revenue Service in the year 1975 and retired as Chief Commissioner of Income-Tax (Central), Delhi after gaining 33 years of work experience. During his career in the Service, he also acted as Joint Secretary of the Tax Policy and Legislation wing at the Foreign Tax and Tax Research Division of the Central Board of Direct Taxes. He was also the Competent Authority for India. He continues to have association with matters relating to direct taxation, particularly in the area of international taxation. He is currently the Principal consultant to the National Institute of Public Finance and Policy, an independent think -tank advising the government in policy matters. He is one of the co-authors of Tax Treaties: Building Bridges between Law and Economics ; Beneficial Ownership- Recent Trends ; Tax Treaty Case Law around the Globe (2013),(2014); BRICS and the Emergence of International Tax Coordination [IBFD]; and The Impact of the OECD and UN Model Conventions on Bilateral Tax Treaties [Cambridge]. Stephen E. Shay Stephen E. Shay has been a Senior Lecturer on Law at Harvard Law School since Before joining the Harvard Law School faculty as a Professor of Practice in 2011, Mr. Shay was Deputy Assistant Secretary for International Tax Affairs in the United States Department of the Treasury. While at the Treasury, Mr. Shay contributed to the development of the Foreign Account Tax Compliance Act (FATCA) and the re-launch of the Global Forum on Transparency and Exchange of Information for Tax Purposes. Mr. Shay discloses certain related interests and activities not connected with his position at Harvard Law School on the Harvard Law School website. Prior to re-joining the Treasury Department in 2009, Mr. Shay was a tax partner for 22 years with Ropes & Gray, LLP. Mr. Shay served in the Office of International Tax Counsel at the Department of the Treasury, including as International Tax Counsel, from 1982 to 1987, during which Mr.

Shay actively participated in the development and enactment of international provisions in the Tax Reform Act of 1986. Mr.

He has had extensive practice experience in the international tax area. Mr. Shay is a 1972 graduate of Wesleyan University and he earned his J.D. and his M.B.A. from Columbia University in 1976.

10 Shay actively participated in the development and enactment of international provisions in the Tax Reform Act of Mr. Shay has published scholarly and practice articles relating to international taxation and has testified for law reform before Congressional tax-writing committees. He has had extensive practice experience in the international tax area. Mr. Shay is a 1972 graduate of Wesleyan University and he earned his J.D. and his M.B.A. from Columbia University in Rita Szudoczky Rita Szudoczky has a PhD from the Amsterdam Centre of Tax Law of the University of Amsterdam and works at Loyens & Loeff as a know-how specialist. She lectures at the University of Amsterdam and at the International Tax Centre of Leiden University. Ms Szudoczky has been a speaker on several seminars and conferences on International and European Tax Law and has written various articles and book contributions in these fields. Before starting her PhD research, she worked as a Senior Research Associate for IBFD International Tax Training and in the IBFD Knowledge Center as EU tax law specialist. Before that, she worked as a legal associate in the Tax Department of Berecz & Andrékó Linklaters in Budapest. She has a law degree from Eötvös Loránd University, Budapest, and LLM degrees in International Business Law from Central European University, Budapest, and in European Community Law and International Taxation from the University of Leiden, the Netherlands. John Vella John Vella is an Associate Professor at the Oxford University Centre for Business Taxation (CBT) and a Supernumerary Fellow of Harris Manchester College. He is an expert in:corporate Taxation; Financial Sector Taxation; International Taxation; Tax Avoidance; Tax Administration; Corporate Law. John studied law at the University of

Malta (BA and LLD) and the University of Cambridge (LLM and PhD). Prior to his current post he was Norton Rose Career Development Fellow in Company Law at the Faculty of Law at Oxford.

11 Malta (BA and LLD) and the University of Cambridge (LLM and PhD). Prior to his current post he was Norton Rose Career Development Fellow in Company Law at the Faculty of Law at Oxford. John has been a Proram Affiliate Scholar at New York University and is currently a Deputy Director of the new MSc in Taxation in Oxford and Convenor of the Tax Section of the Uk Society of Legal Scholars. John has given evidence twice before the House of Lords EU Sub-Commmittee A on Financial Transaction Taxes (November 2011 and March 2013) and before the Parliamentary Commission on Banking Standards on the role of tax in relation to banking standards and culture (January 2013). He has acted as a co-arbitrator in a tax dispute before the ICC International Court of Arbitration. Peter Wattel Peter Wattel has been a professor of EU tax law at the University of Amsterdam, the Netherlands, since 1992 and an Advocate-General in the Hoge Raad der Nederlanden (Netherlands Supreme Court) since Before that, he was a finance trainee with the Royal Dutch Shell Group and a senior assistant professor at the Universities of Maastricht (private law) and Amsterdam (tax law), the Netherlands. He served as a substitute judge in the Courts of Appeal of Amsterdam (criminal chamber) and Den Bosch (tax chamber), and was Of Counsel to EY Tax Advisers. He teaches EU tax law, international tax law and tax procedure as part of the national and international curricula of the University of Amsterdam. He has published eight books, including the world standard reference work on European tax law (with Ben Terra) and some 400 articles and comments on law and taxation. He is a member of the Royal Netherlands Academy of Sciences and of the editorial board of the Nederlands Juristenblad (the leading general law review in the Netherlands).

Dennis Weber Dennis Weber (1970) is a professor of European Corporate Tax Law at the University of Amsterdam and director and founder of the Amsterdam Centre for Tax Law (ACTL).

12 Dennis Weber Dennis Weber (1970) is a professor of European Corporate Tax Law at the University of Amsterdam and director and founder of the Amsterdam Centre for Tax Law (ACTL). He is one of the founders of the Group for European and International Taxation (GREIT) and founder of the EU Tax Law Group. He is the general editor and founder of the Journal Highlights & Insights on European Taxation. He is also a guest lecturer at various universities worldwide. He is affiliated to Loyens & Loeff as of counsel, where he is in charge of the European tax law team. As part of his duties, he is involved in numerous proceedings in the field of European tax law for Dutch courts, the European Court of Justice (such as Verkooijen and the D-case) and foreign courts (Unilever pensioenfonds; Conseil d'etat), and acts consultant, mainly to multinational organisations. Weber is the author of a book entitled Tax avoidance and the EC treaty freedoms (2005), and of In search for a (new) equilibrium between tax sovereignty and the freedom of movement within the EC in inaugural lecture (2006) and has published more than 45 articles on European tax law in national and international professional journals, such as the Weekblad Fiscaal Recht (Tax Law Weekly), FED Fiscaal weekblad (FED Tax Weekly), European Taxation, EC Tax Review and Intertax. He has also published more than 150 tax columns in various Dutch newspapers. He edited 6 books. Weber is coordinator of the International and European Tax Law program of the Nederlandse Orde van Belastingadviseurs (Netherlands Association of Tax Lawyers: NOB), a board member of the NOB s European tax law section, and a member of the European Tax Law Group, an independent group of tax lawyers who focus on European tax law. Weber is a deputy judge at the Den Bosch Court of Appeal, where he is primarily involved in cases related to European tax law.

Contributors. Kim Brooks is Dean at the Schulich School of Law at Dalhousie University in Halifax, Canada.

Contributors. Kim Brooks is Dean at the Schulich School of Law at Dalhousie University in Halifax, Canada. Reuven Avi-Yonah is the Irwin I. Cohn Professor of Law and Director of the International Tax LLM Program at the University of Michigan, specializing in corporate and international taxation. He has served