Expertise

Where Tax Law
Meets Global Complexity.

We operate at the intersection of international tax law, investment treaty arbitration, international trade law, public international law and global tax policy — a space thriving with unique cases we enjoy to meticulously analyse.

The double hybrid advantage.

Our advice flows through a joint vision of tax law and global tax policy in light of geopolitical developments — combining what is usually kept apart.

01 ·

Academia + Practice

Combining scholarly rigor with market experience. We bring together academic rigor and decades of experience as practicing attorneys, experts, and tax policy counsel to governments and businesses.

02 ·

Tax Law + International Investment Law + International Trade Law + Public International Law

Unique cross-section across legal regimes. We aim to deploy our expertise in international tax law in the context of international investment law and the dynamics of investment treaty arbitration.

Service pillars

What engagements we may accept

01

Expert Witness & Special Counsel (Investment Arbitration)

Acting as tax expert witness in investment arbitration and before courts and as special tax counsel for arbitration and litigation teams.

Examples of client challenges:

  • Your government is facing a tax-related ISDS claim and needs an independent expert report on the tax-related dispute.
  • Your client — a major investor — decided to arbitrate or litigate against a State and requires an independent expert report on the root of the tax-related dispute.
  • Your tax litigation, investment treaty arbitration or trade dispute team is handling high-level cross-border controversy and will benefit from independent and in-depth expertise in tax, investment treaty or trade treaty related matters.
02

Strategic International Tax Analysis & Reports

Analysis for multinational corporations, governments and supranational organizations on topics such as: tax treaties, investment treaties, BEPS, Pillar Two, beneficial ownership, CFC rules, digital service taxes.

Examples of client challenges:

  • You require precise tax analysis of the tax treaty entitlements of your holding entities and underlying active subsidiaries.
  • Your sovereign wealth fund requires an independent tax expert report on exposure to tax risk regarding current or new cross-border investment structures.
03

Policy & Dispute Prevention

Analysis and early-stage expert opinions for governments and supranational organizations regarding legislation and dispute prevention.

Examples of client challenges:

  • Your ministry needs to assess the compatibility of new tax measures with investment treaty obligations.
  • Your international organization requires policy analysis on the intersection of AI and tax law.
Work with us

Engage us

Tell us about your matter. We will let you know – promptly and candidly – whether and how we can help.

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