Is there evidence of increasing harmonisation in the interpretation of tax treaties in courts through their reference to foreign court decisions?
This might not be a typical dinner-table exchange, but four UCT students would be able to answer that question with world-class authority.
A team of tax master’s students won a prestigious international tax law competition, having submitted a research paper that answered that question better than all the papers submitted by their compatriots from around the world.
Rui Carvalho, Imran Daniels, Michael Dewar and Waleed Sahabodien, who were part of the 2016 master’s cohort at UCT, won the first Global Tax Treaty Commentaries (GTTC) Universities Project. With Associate Professor Craig West as their coach, they beat a student team from McGill University in Canada in the finals in May 2017.
Daniels and Sahabodien travelled to Amsterdam for the oral presentations of their methodology and findings, and to claim their prize. Their feat was made all the more impressive by the fact that they were competing against 24 other teams from universities across the globe.
The judging panel comprised Professor Frans Vanistendael, emeritus professor at the University of Leuven and former academic chairman of the International Bureau of Fiscal Documentation (IBFD); Professor Pasquale Pistone, current academic chairman of the IBFD and professor at Salerno University and the Vienna University of Economics and Business; and Dr Irma Mosquera, senior research associate and GTTC technical editor at the IBFD. The IBFD organised the competition and funded the two students’ travel to Amsterdam.
The judges evaluated the papers according to the relevance of the students’ research, the scientific quality, the results of the review and the analysis of the sources used. Some of the working papers will be published in a dedicated supplement to an IBFD journal or in the IBFD World Tax Journal.
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