ÐÓ°ÉÂÛ̳

 Eduardo Baistrocchi

Eduardo Baistrocchi

Associate Professor of Law

ÐÓ°ÉÂÛ̳ Law School

Telephone
020-7955-6395
Room No
Cheng Kin Ku Building 7.33
Languages
English, Spanish
Key Expertise
Corporate and international taxation

About me

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, Harvard Law School and ÐÓ°ÉÂÛ̳. He has been a Distinguished Visiting Professor at FGV Direito São Paulo, Northwestern University and the University of Toronto. 

Prior to his academic career, he served as Law Clerk to Chief Justice Petracchi at the Supreme Court in Argentina. He then practised tax law in leading law firms in Buenos Aires and São Paulo, Brazil. He has been a Chevening Scholar and Fulbright Scholar.

His research focuses on international and corporate taxation. He has published in leading journals and publishing houses such as the British Tax ReviewFlorida Tax ReviewGlobal Tax Treaty Commentaries, the Modern Law ReviewVirginia Tax Review, the Oxford Journal of Legal Studies and Cambridge University Press.

He is the principal author and editor of the .

Administrative support: Law.Reception@lse.ac.uk

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.

 

click here for video presentations from ÐÓ°ÉÂÛ̳ 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)

Reuven S. Avi-Yonah, “Are Taxes Converging?”, Tax Notes International, 27 November, 2017, pp. 889-891 (United States of America)

Parthasarathi Shome, Global Trends in Tax Disputes, Business Standard, 30 November 2017 (India)Standard (India)

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)

Violeta Ruiz Almendral, Crónica Tributaria, N° 166, 2018, Instituto de Estudios Fiscales, pp. 239-242 (Spain)

Kim Brooks, Canadian Tax Journal, 2018, 66:2, pp. 507-508 (Canada)

Luís Eduardo Schoueri, Revista Direito Tributário Internacional Atual nº 03 p.159-162 – 2018 (Federative Republic of Brazil)

Marcus Livio Gomes, Revista de Direito Internacional Econômico e Tributârio, Brasília, V. 12, nº2, p. 1-5 Jul-Dez, 2017 (Federative Republic of Brazil)

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.


[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]

Articles

  •  Florida Tax Review (December 2024) 27 (2) 43 pages
  •  Global Tax Treaty Commentaries (2024) IBFD, The Netherlands, 75 pages 
  • Global Topics IBFD, December 2023, The Netherlands
  • 'International Taxation, the G-7, and India: A Proposal', Tax Notes International, October 30, 2023, p. 653, 
  • United Kingdom Policy and Practice (December 6, 2022). Global Tax Treaty Commentaries, IBFD, The Netherlands., Available at SSRN: 
  • Article 9: Associated Enterprises - Global Tax Treaty Commentaries (December 20, 2022). Global Tax Treaty Commentaries, IBFD, the Netherlands., Available at SSRN: 
  • Global Tax Treaty Commentaries, International Bureau of Fiscal Documentation, 2022
  • International Bureau of Fiscal Documentation, pp.1 – 54, 2021
  • ' (Winter 2021). Virginia Tax Review, Vol. 40, No. 02
  • (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.
  • (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), (Cambridge University Press, 2017)
  • in E. Baistrocchi (ed), (Cambridge University Press, 2017)
  • 'Tax Treaty Disputes: A Global Quantitative Analysis´ in E. Baistrocchi (ed), (Cambridge University Press, 2017) (with Martin Hearson)
  • Oxford Journal of Legal Studies, 2013
  •   in Eduardo A Baistrocchi and Ian Roxan (eds), Resolving Transfer Pricing Disputes: A Global Analysis (Cambridge University Press 2012)
  • Modern Law Review (2012), Volume 75, Issue 4, 547-577
  • (September 24, 2008). British Tax Review, No. 4, 2008
  • (Summer 2006). Tax Lawyer, Summer 2006
  • Tax Notes International, pp. 241-255, October 18, 2004
https://research.ibfd.org/#/doc?url=/document/gttc_article9_chaphead