Winner 2024
Savvas Kostikidis (Greece/ Germany) - Nexus for Source Taxation of Mobile Individual Service Providers in Tax Treaties.
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 2024 Congress in Cape Town, South Africa, exempted from the payment of the Congress registration fee, during which the Prize is awarded.
Submission deadline: 30 May 2024, by e-mail.
Please contact the IFA General Secretariat for further details at [email protected].
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 |
|
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) |