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. i potem

02 ·

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

Unique cross-section across legal regimes.

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; 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. Tax 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 for governments and supranational organizations. Legislation, dispute prevention, early-stage expert opinions.

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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