Rules 2025
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 2025 Congress in Lisbon, Portugal, exempted from the payment of the Congress registration fee, during which the Prize is awarded.
Submission deadline: 15 May 2025, by e-mail.
Please contact the IFA General Secretariat for further details at [email protected].
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.
2024 |
Winner | Savvas Kostikidis - Greece/ Germany | Nexus for Source Taxation of Mobile Individual Service Providers in Tax Treaties |
2023 |
Winner | Benjamin Malek - Switzerland | Beneficial Ownership and Income Receipt under Double Taxation Conventions: Considerations following the Planet Case |
2022 |
Winner | Prerna Kishore Peshori - India | Obligation to provide double taxation relief in the case of hybrid entities under the 2017 OECD Mode |
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 |
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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) |