Centre for Commercial Law Studies

Dr Christiana HJI Panayi, BA BCL PhD

Christiana

Professor in Tax Law

Email: c.hji-panayi@qmul.ac.uk
Telephone: +44 (0)20 7882 8105

Profile

Christiana is a Professor in Tax Law at Queen Mary University of London. She teaches on the EU Tax Law, International Tax Law and Transfer Pricing courses of the LLM Programme. Christiana is also a researcher at the Institute for Fiscal Studies. In the past, Christiana was also an Adjunct Professor of European Union Tax Law at New York University, a Visiting Professor at Sorbonne University (Ecole de droit de la Sorbonne, Université Paris 1) and a Visiting Professor at the University of Lausanne.

Christiana has published extensively in the area of EU and International Tax Law and is considered a leading expert in her field. Since appointed at Queen Mary in 2006, Christiana’s research outputs were included in both RAE 2008 and REF 2014. Christiana’s book entitled European Union Corporate Tax Law was published by Cambridge University Press in 2013. This was the first book to be published in the area and has received excellent reviews. Christiana’s subsequent book, entitled Advanced Issues in International and European Tax Law, was published by Hart Publishing in 2015. This book also received excellent reviews and was cited by the US Treasury in its White Paper on the on European Commission’s State Aid Investigations into Transfer Pricing Rulings. Her latest book, an edited book entitled Research Handbook on European Union Taxation Law was published in 2020 by Elgar Publishing.

Christiana speaks regularly at tax conferences and teaches abroad. She has lectured at New York University, the University of Cambridge, Boston College, the University of Lausanne, the Chartered Institute of Taxation, the European Commission, the Academy of European Law, the Vienna University of Economics and Business Administration, the University of Lisbon, the University of Amsterdam and various other universities. She has also designed and conducted workshops on International and EU tax law for Her Majesty’s Revenue and Customs, the UK Treasury and various south European organizations and accounting firms.

Christiana has been appointed twice as an expert member at the European Commission’s Joint Transfer Pricing Forum (JTPF) and the Platform for Tax Good Governance. She is currently serving her second term as an expert member of the Platform for Tax Good Governance. She is also a member of the BEPS Monitoring Group, a member of the European Association of Tax Law Professors and a member of the Examination Sub-Committee of the ADIT (Advanced Diploma in International Taxation). In the past, she was external examiner at the University of Dundee and University College Dublin.

Christiana studied at Oxford University for her BA in Jurisprudence and for the BCL. She also has a PhD from the London School of Economics. She is a solicitor of England and Wales and an advocate of the Cyprus Supreme Court. Before joining Queen Mary, Christiana worked for Allen and Overy LLP. Christiana is also a member of the Law Society of England and Wales, and the Cyprus Bar Association.

Research

Research Interests:

Christiana’s research interests are in the area of European Union tax law, international tax law, tax treaties, transfer pricing, tax policy and good tax governance. She also has an interest in international treaty law and EU state aid law.

Publications

Christiana HJI Panayi's SSRN page

Books

  • European Union Corporate Tax Law (Cambridge University Press); ISBN: 9781107018990 (pp.1-416, excluding preliminaries)
    • Review: “It is a comprehensive analysis of EU corporate tax law, demonstrating great knowledge and insight. It represents a great addition to existing literature and—this reviewer has no doubt—will soon become a reference in this area”. See [2013] 5 BTR pp. 691-694.
    • Review: “An excellent and complete overview of EU taxation: Christiana provides a simple and enjoyable overview of very complex issues and legal doctrines”. Pierpaolo Rossi of European Commission Legal Services
  • The Common Consolidated Corporate Tax Base and the UK, Institute for Fiscal Studies, 2011; ISBN 978-1-903274-57-6
  • Double Taxation, Tax Treaties, Treaty Shopping and the European Community, Kluwer Law International, EUCOTAX Series 2007; ISBN/ISSN 9041126589
    • Review: “This book […] is both comprehensive and insightful. As Philip Baker QC comments in the Foreword, “many of the issues covered in this book are ones that the European Community is just beginning to consider” (p.xii). [...] In the meantime, Christiana Panayi's book offers the reader the opportunity to reflect on some of the obstacles before us, as well as on possible outcomes. As the author rightly observes, “these are certainly interesting times, even in tax law””. See [2008] 1 British Tax Review 96-98.
    • Winner of tax thesis award of European Commission and European Association of Tax Law Professors (2007)
  • Advanced Issues in International and European Tax Law (Hart Publishing, 2015). ISBN: 9781849466950
    • Review: “Professor HJI Panayi’s unique and most valuable book has the potential of becoming the turning point in this increasingly complex field”. See review in [2016] 44 Intertax.
    • Review:A book like this is a well-designed guide for those coming to the area for the first time, as well as a record for the future […]. It is a welcome addition to the literature in the fields of both international taxation and EU direct taxation.” (Book Foreword by Philip Baker QC).
    • This book was cited, inter alia, by the US Treasury in its White Paper on the on European Commission’s State Aid Investigations into Transfer Pricing Rulings
  • Research Handbook on European Union Taxation Law (Elgar Publishing, 2020) – edited together with Werner Haslehner and Edoardo Traversa. ISBN: 978 1 78811 083 9 (1-645, excluding preliminaries)
    • Review: “Written in a clear and entertaining style, this book succeeds in providing a solid analytical basis for future debate and research on the subject of EU taxation law. It is a thoughtful and rigorous study that addresses a challenging set of questions for scholars and students. Overall, it is an excellent contribution to the legal literature on European Union law …” (Foreword by Koen Lenaerts)

Chapters in Books

  • “European Tax Law: Legislation and Political Initiatives", in Gore-Browne on EU Company Law (Jordan Publishing); ISBN: 0853084009
  • European Community Tax Law and Companies: Principles of the European Court of Justice”, in Gore-Browne on EU Company Law (Jordan Publishing); ISBN: 0853084009
  • “Inbound investment and thin capitalization”, in The Common Consolidated Corporate Tax Base (Linde, 2008) pp.821-845; ISBN: 978-3-7073-1306-2 (jointly with Malcolm Gammie)
  • “UK Corporate Residence”, in Residence of Companies under Tax Treaties and EC Law (EC and International Tax Law Series, volume 5, IBFD Publications, 2009), pp.817-854; ISBN: 978-90-8722-056-3
  • “Harmonization and Direct Taxes – Is it Really Needed?” in Studies in European Public Law: Thematic, National and Post-National Perspectives (Sakoulas Publications, 2010); ISBN: 978-960-445-530-0
  • “Rethinking treaty-shopping: Lessons for the European Union”, in Tax Treaties: Building Bridges between Law and Economics (IBFD Publications, 2010), pp.18-50; ISBN: 978-90-8722-085-3 (jointly with Reuven Avi-Yonah)
  • “CFC rules within the CCCTB”, in Corporate Income Taxation In Europe - The Common Consolidated Corporate Tax Base (CCCTB) and Third Countries (Elgar Publishing, 2013) – ISBN: 978 1 78254 541 5
  • “Cyprus Tax Treaty Dispute Resolution”, in Resolving Tax Treaty Disputes: A Global Analysis (Cambridge University Press, 2016) pp.1140-1195; ISBN: 9781316528945
  • “The ATAD CFC rule and its impact on the existing regimes of EU Member States”, in The Implementation of the Anti-BEPS in the European Union: A Comprehensive Study (IBFD, 2018)
  • “CFC Rules under EU Tax Law – The Legacy of Cadbury Schweppes”, in Landmark Cases in Revenue Law (Hart Publishing, 2018)
  • “The Early Proposals for a European Corporate Tax Policy”, in Studies in the History of Tax Law vol.9 (Hart Publishing, 2019)
  • “Tax justice in the post-BEPS era: enhanced cooperation among tax authorities and the protection of taxpayer rights in the EU”, in Tax Justice and Tax Law: Understanding Unfairness in Tax Systems (Hart Publishing, forthcoming)
  • “The Harmonisation of Direct Tax Law” in EU Fiscal Federalism: Past, Present, Future (OUP, forthcoming)

Journal Articles

  • “Open Skies for European Tax?”, [2003] British Tax Review 189-202 (Sweet & Maxwell); ISSN: 0007-1870
  • “Limitation on Benefits and State Aid”, 44 [2004] European Taxation 83-98 (IBFD Publications); ISSN: 0014-3138
  • “State Aid and Tax: The Third Way?”, 32 [2004] Intertax 287-311 (Kluwer Law International); ISSN: 0165-2826
  • “Ships and Taxes: Does the Case of Commission v. Netherlands have Tax Implications?”, 45 [2005] European Taxation 97-102; ISSN: 0014-3138
  • “Family Office: Wealth Management in the 21st Century”, Trusts and Estates Law & Tax Journal, May 2005; ISSN: 1743-5501
  • “Agency Permanent Establishments in Securitisation Transactions”, 33 [2005] Intertax 286-296; ISSN: 0165-2826
  • “The Schempp case: A new leaf in the jurisprudence of the Court of Justice or just a fig leaf?”, 45 [2005] European Taxation 482-487; ISSN: 0014-3138
  • “Treaty-shopping and other tax arbitrage opportunities in the European Union: A Reassessment – Part 1”, 46 [2006] European Taxation 104-111; ISSN: 0014-3138
  • “Treaty-shopping and other tax arbitrage opportunities in the European Union: A Reassessment – Part 2”, 46 [2006] European Taxation 139-155; ISSN: 0014-3138
  • “Exploring the Open Skies: EC-incompatible treaties between Member States and Third Countries”, [2006] Yearbook of European Law 315; ISBN: 0263-3264
  • “Multistate Cumulative Tax Burdens and Reliefs in the European Community - Lessons from the United States”, 47 [2007] European Taxation 15; ISSN: 0014-3138
  • “The Protection of Third-Country Rights in Recent EC Case Law”, Tax Notes International, 19 February 2007; ISSN: 1058-3971
  • “The Effect of Community Law on Pre-Accession Tax Treaties”, 16/3 [2007] EC Tax Review 120; ISSN: 0928-2750
  • “Thin Capitalisation GLO et al. – a thinly concealed agenda?”, 35 [2007] Intertax 298; ISSN: 0165-2826
  • “Tax Treaty Law and Community Law – Some Recent Developments”, [2007] 3 EC Tax Journal 10; ISSN: 1350-1089
  • “Recent Developments to the OECD Model Tax Treaty and EC Law”, 47 [2007] European Taxation 452; ISSN: 0014-3138
  • “The Common Consolidated Corporate Tax Base: Issues for Third Countries and Member States opting out”, 48 [2008] European Taxation 114; ISSN: 0014-3138
  • “The Fundamental Freedoms and Third Countries”, 48 [2008] European Taxation 571; ISSN: 0014-3138
  • “The proposed amendments to the Savings Directive”, 49 [2009] European Taxation 179
  • “Corporate Mobility under Private International Law and European Community Law: Debunking Some Myths”, [2009] Yearbook of European Law 124-176
  • “Tax Treaties post-Damseaux”, [2009] Tax Journal, 14 September 2009, 9
  • “Corporate mobility in the European Union and Exit Taxes”, [2009] Bulletin for International Taxation 459
  • “Rethinking Treaty-Shopping: Lessons for the European Union”, [2010] International Taxation, volume 2, issue 1, p.15
  • “Reverse Subsidiarity and Cross-border loss relief: Can Member States be left to their own devices?”, 55 [2010] 3 British Tax Review 267-301
  • “Exit taxation as an obstacle to corporate emigration from the spectre of EU tax law”, [2011] Cambridge Yearbook of European Legal Studies 245
  • “Anti-abuse rules within the CCCTB”, [2012] 4/5 Bulletin for International Taxation 256
  • “National Grid Indus BV v Inspecteur van de Belastingdienst Rijnmond/kantoor Rotterdam: Exit taxes in the European Union revisited” [2012] 1 British Tax Review 41- 49; ISSN: 0007-1870
  • “The Taxation of Permanent Establishment in EU Tax Law: Selected Issues”, [2013] 4/5 Bulletin for International Taxation pp.226-237; ISSN: 0007-4624
  • Under the EU’s proposed Financial Transactions Tax, non-participating member states may bear the burden of deeper tax integration without reaping the benefits”, on the Europp blog of the London School of Economics
  • “The EU’s Financial Transaction Tax, Enhanced Cooperation and the UK’s challenge” [2013] 8 European Taxation pp.358-367; ISSN: 0014-3138
  • “Is Aggressive Tax Planning Socially Irresponsible?” [2015] 10 Intertax 543-557
  • “The Compatibility of the OECD/G20 Base Erosion and Profit Shifting Proposals with EU Law”, 70 [2016] 1/2 Bulletin for International Taxation pp.95-112; ISSN: 0007-4624
  • “Are the BEPS Proposals Compatible with EU Law – Part 1”, Bloomberg BNA Tax Planning International Review, January 2016, pp.1-6; ISSN: 0309-7900
  • “Current Trends on Automatic Exchange of Information”, SMU School of Accountancy (January 2016)
  • “Are the BEPS Proposals Compatible with EU Law – Part 2”, Bloomberg BNA Tax Planning International Review, February 2016, pp.1-9; ISSN: 0309-7900
  • “If you want Google to pay more tax, change the law”, in the Conversation
  • “Are the BEPS Proposals Compatible with EU Law – Part 3”, Bloomberg BNA Tax Planning International Review, March 2016; ISSN: 0309-7900
  • “Are the BEPS Proposals Compatible with EU Law – Part 4”, Bloomberg BNA Tax Planning International Review, April 2016; ISSN: 0309-7900
  • “International Tax Law in the Post-BEPS Worlds”, [2016], available at: http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2785480
  • “International Tax Law following the OECD/G20 Base Erosion and Profit Shifting Project”, [2016] 11 Bulletin for International Taxation 628-660.
  • “EU tax developments in 2016”, (2016) Tax Journal, Issue 1336, 12-17
  • The Europeanisation of Good Tax Governance”, 36 (2018) 1 Yearbook of European Law 442-495.
  • The Peripatetic Nature of EU Corporate Tax Law”, 24 (2019) Deakin Law Review (https://ojs.deakin.edu.au/index.php/dlr/article/view/870 ) 1-60

Peer-Reviewed Articles

  • “Open Skies for European Tax?”, [2003] British Tax Review 189-202 (Sweet & Maxwell); ISSN: 0007-1870
  • “Agency Permanent Establishments in Securitisation Transactions”, 33 [2005] Intertax 286-296; ISSN: 0165-2826
  • “Exploring the Open Skies: EC-incompatible treaties between Member States and Third Countries”, [2006] Yearbook of European Law 315; ISBN: 0263-3264
  • “Corporate Mobility under Private International Law and European Community Law: Debunking Some Myths”, [2009] Yearbook of European Law 124-176
  • “Reverse Subsidiarity and Cross-border loss relief: Can Member States be left to their own devices?”, 55 [2010] 3 British Tax Review 267-301
  • “Exit taxation as an obstacle to corporate emigration from the spectre of EU tax law”, [2011] Cambridge Yearbook of European Legal Studies 245
  • “Is Aggressive Tax Planning Socially Irresponsible?” [2015] 10 Intertax 543-557
  • The Europeanisation of Good Tax Governance”, 36 (2018) 1 Yearbook of European Law 442-495.
  • The Peripatetic Nature of EU Corporate Tax Law”, 24 (2019) Deakin Law Review (https://ojs.deakin.edu.au/index.php/dlr/article/view/870 ) 1-60

Supervision

Dr Christiana HJI Panayi welcomes proposals for PhD supervision in the area of international tax law and European tax law. Her current PhD students are:

  • Bruno Simoes: “Tax coordination of life assurance Investment-Linked Policies (ILPs) in the European Union”
  • Niko Sievert: “International Corporate Taxation of MNEs in the Middle East and North Africa: The Challenges of Modernisation and Integration”
  • Jonas Bley: “The UN Model Tax Convention - tax treaties with developing countries and emerging states”
  • Martin Harty: “Whose tax is it anyway? Value creation, intangibles, and the right to tax the income of multinational enterprises”
  • Aleksandar Ivanovski: “Interaction of EU State Aid Rules and Tax Law: Towards a Sustainable Tax Rulings framework”
  • David Quentin: “A Materialist Political Economy of Corporate Tax”.

She has also completed PhD supervision with the following students:

  • Jeanette Calleja Borg: “Cross-Border Group Loss Relief in the EU”
  • Murray Clayson: “The Recognition of the Effect of Passive Association on Controlled Transactions for Transfer Pricing Purposes”
  • Peter Wilson: “BRICS and International Tax Law”.

Public Engagement

Professional activities, memberships and outreach

  • Member of the Institute of Tax Law at the Centre for Commercial Law Studies
  • Adjunct Professor at NYU
  • Visiting Professor at Sorbonne University
  • Member of the Joint Transfer Pricing Forum of the European Commission
  • Member of the Platform for Tax Good Governance of the European Commission
  • Solicitor of the Law Society of England and Wales
  • Advocate of the Cyprus Supreme Court
  • Member of the BEPS Monitoring Group (BMG)
  • Member of the International Network of Tax Research of the OECD
  • Research fellow of the Tax Law Review Committee of the Institute for Fiscal Studies
  • Member of the European Association of Tax Law Professors
  • Examiner of the Chartered Institute of Taxation - Member of the Examination Sub-Committee of the ADIT

Public speaking engagements

2019

  • Speaker at University of Luxembourg seminar, in November 2019 (jointly with Katerina Perrou)
  • Speaker at IFA 2019, in panel on Tax Morale
  • Speaker at the Cambridge Tax Policy conference at the University of Cambridge in July 2019
  • Speaker at the Oxford conference (The Dynamics of Taxation) in honour of Judith Freedman in May 2019
  • Speaker at the Common Law conference organised by the British High Commission and the University of Cyprus in March 2019
  • Speaker at the International Tax Conference in February 2019

2018

  • Conducted seminar on my paper The Europeanisation of Good Tax Governance at the tax faculty of New York University, in January 2018.

2017

  • Speaker at workshop on Fiscal Federalism at Cambridge University in July 2017. Title of Paper: “The Harmonisation of EU Direct Tax Law”.

2016

  • Organised seminars on EU Tax Law at Altium Training Greece (December 2016)
  • Organised seminars on EU Tax Law at the Malta Institute of Management (October 2016)
  • Participated as an expert at the meeting of the Platform for Tax Good Governance (September 2016)
  • Participated as an expert at the meeting of the Platform for Tax Good Governance (June 2016)
  • Speaker at conference of University of Amsterdam. Title of conference: “Anti-BEPS Implementation in the EU”. Title of paper: “The CFC provision of the proposed Anti-Tax Avoidance Directive” (June 2016)
  • Speaker at Cambridge University’s Tax Policy Conference (April 2016)
  • Guest speaker at the London School of Economics tax seminars (March 2016)
  • Participated at the OECD meetings of the steering group of the International Network of Tax Research (February-March 2016)
  • Participated as an expert at the meeting of the Joint Transfer Pricing Forum (February 2016).

2015

  • Speaker at the Athens Tax Forum, organised by the American Hellenic Chamber of Commerce (April 2015)
  • Lectured LLM students at the University of Lausanne, on the topic of mergers and reorganisations (April 2015)
  • Lectured at NYU, at the international tax programme (March 2015)
  • Plenary speaker at the Annual International Tax Conference of the Malta Institute of Management. Title of conference: “Taxpayers’ rights in a changing international landscape”. Title of paper: “Tackling Tax Avoidance in the European Union”.

2014

  • Speaker at conference organised by the American-Hellenic Chamber of Commerce in March 2014. Title of conference: “10th Athens Tax Forum”. Title of paper: “Tax Avoidance Internationally and in the European Union”
  • Organised seminars on EU Tax Law at the Malta Institute of Management.

2013

  • Speaker at conference organised by the London School of Economics in November 2013. Title of conference: “Resolving Tax Treaty Disputes: A Global Analysis”. Plenary speaker. Also contribution of paper entitled: “Resolving Tax Treaty Disputes in Former Tax Havens”
  • Organised and conducted the Queen Mary – HM Treasury/HMRC training seminars on EU Tax Law in January-February 2013.

2012

  • Organised and conducted training seminars for top ranking employees at HM Treasury and HMRC on the topic of the Common Consolidated Corporate Tax Base in October 2012. Speaker at conference organised by the University of Lisbon in June 2012. Title of conference: “EU Tax Policy Conference”. Title of paper: “The CCCTB: Selected Issues”
  • Taught a one-day workshop at the Cambridge Centre for Tax Law in May 2012. Gave paper on the CCCTB and Anti-Abuse rules
  • Speaker at conference organised by the Institute for Austrian and International Tax Law of the Vienna University of Economics and Business Administration in January 2012. Title of conference: “CCCTB and Third Countries”. Title of paper: “The CFC rules within the CCCTB”.

2011

  • Organised the KPMG International Tax Law Conference in Cyprus in April 2011, with speakers from the European Commission, leading UK tax barristers and others
  • Organised seminars on EU Tax Law at the Malta Institute of Management.

2010

  • Speaker at conference organised by the Institute for Austrian and International Tax Law of the Vienna University of Economics and Business Administration in March 2010. Title of conference: “Tax Treaties Issues from a Legal and Economic Perspective”. Title of paper: “Rethinking treaty-shopping: Lessons for the European Union”.
  • Speaker at the Chartered Institute of Taxation seminars in January 2010. Title of paper: “Marks & Spencer and UK Group Relief Rules: A never ending saga?”.

2009

  • Organised the KPMG International Tax Law Conference in Cyprus in October 2009, with speakers from the European Commission, leading UK tax barristers and others
  • Organised seminars on EU Tax Law at the Malta Institute of Management.

2008

  • Conference organised by the University of Cyprus in October 2008. Title of conference: “Harmonisation in Practice: The Paradigm of European Public Law”. Title of paper: “Harmonisation and Direct Taxes: Is it really needed?”
  • Conference organised by the Institute for Austrian and International Tax Law of the Vienna University of Economics and Business Administration, in cooperation with the Taxation and Customs Union DG of the European Commission, in February 2008. Title of conference: “Common Corporate Consolidated Tax Base: The Possible Content of Community Provisions.” Title of paper: “Thin Capitalisation and Inbound Investment”.

2007

  • Speaker at conference organised by the Academy of European law (ERA Congress), in Trier, Germany in October 2007. Title of conference: “Does competition law still allow for tax planning by European firms? How to reconcile taxation and state aids.” Title of paper: “UK System: Tax Benefits for UK offshores”.

2006

  • Speaker at Fiscalis Seminar entitled “Tax Treaties and EC Law”, organised by the European Commission in October 2006. Title of paper: “Effects of the Accession Treaty on pre-existing tax treaties: legal aspects”. Subsequently published in EC Tax Review (2007) vol.3.

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