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Publications

LECTURES AND SPEAKING ENGAGEMENTS

  • ‘Developing an effective dispute resolution mechanism for the BRI’, Reducing & Resolving Cross Border Tax Disputes along the Belt & Road Initiative (BRI), Yangzhou, China, June 13, 2019

  • ‘BEPS Action 1 – Would consensus be reached?’ & ‘POEM: Is it a still born concept?’ at the IFA Mauritius 13th Asia/Africa Conference 2019, Mauritius, May 9-10, 2019

  • ‘Principal Purpose Test (PPT) – the new form over substance test – GAAR (General Anti-avoidance Rules) / POEM – experiences and perspective’ & ‘Tax Dispute Resolution in post BEPS world (Alternate dispute resolution, MAP and AAR)’ at the IBFD-IFA India International Taxation Conference, 2019, New Delhi, India, April 26-27, 2019

  • ‘Dispute Resolution in Tax Treaties – Past, Present & Future’, Excellence Course in International Tax Law & Policy (LL.M.), Maastricht University, Maastricht, Netherlands, March 8, 2019

  • ‘Alternative Dispute Resolution and Arbitration In International Tax Matters – the OECD MLI and the Dispute Resolution Directive’, International Tax Cooperation Congress 2019, Barcelona, Spain, January 18, 2019

  • ‘Royalties: Cross-border software planning; Leasing transactions’ (with Mirna Screpante), The Practice of Double Tax Treaties in Case Studies – Senior level course, Vienna, Austria (2019-present)

  • ‘The working of the OECD MLI: Public International Law Perspective’, IFA India Southern Regional Chapter Event, Chennai, India, December 22, 2018

  • ‘The EU Digital Services Tax: A comparison with the Indian Equalization Levy’, IBFD-FIT International Taxation Conference, 2018, Mumbai, India, December 6-8, 2018

  • ‘The OECD MLI: Public International Law Perspective’, KPMG India Conference on Emerging International Taxation and Transfer Pricing Trends, Mumbai, India, December 5, 2018

  • ‘Source Taxation’, Introduction to Tax Treaty Law, WU, Vienna, Austria (2017-present)

  • ‘The Anti-Tax Avoidance Directive’ (with Stephanie Zolles), CEE Summer School, WU, Vienna, Austria (2018 – present)

  • ‘Tax Litigation in India’, Tax Treaty Arbitration, Rust (Burgenland), Austria, July 5 – 7, 2018

  • ‘The EU Digital Services Tax Proposal’, ACTL-IBFD-Conference: Taxing the digital economy: the EU proposals and other insights, Amsterdam, Netherlands, June 28, 2018

  • ‘Personal Scope of the MAP, Arbitration and Mutual Assistance Provisions’, Viennese Symposium on International Tax Law, Vienna, Austria, June 22, 2018

  • ‘Mandatory Arbitration under Part VI of the MLI’, 15th GREIT Conference on ‘Multilateralism in Tax Law’, Lisbon, Portugal, June 19, 2018

  • ‘Fundamental inequities in the allocation of taxing rights under tax treaties: Issues and Possible Solutions’, Academic Seminar on ‘The Role & Design of Tax Treaties in a Global Integrated Economy’, Vienna, Austria, February 6, 2018

  • ‘The Experience of Developing and Emerging Economies with MAP’, 5th meeting of Vienna Multi-Stakeholder Group on Improving Cross-border Dispute Resolution, Mexico City, Mexico, January 24, 2018

  • YIN Seminar, Place of Effective Management, Tax Treaty Abuse and Permanent Establishments, IFA Congress, Rio de Janeiro, Brazil, August 29, 2017

  • ‘Non-Discrimination rule in Tax Treaties’, ‘Qualification and Allocation Conflicts’, ‘Tax Treaty Abuse: BEPS’, ‘Interpretation of Tax Treaties’ (with David Orzechowski), ‘Passive Income’ (with Alexandra Miladinovic), Xiamen Summer School on ‘Special Issues in Tax Treaty Law’, Xiamen University, Xiamen, China, July 17-21, 2017

  •  ‘Judicial Anti-avoidance Rules in India’, Implementing Key BEPS Actions: Where do we stand?, Rust (Burgenland), Austria, June 29 – July 1, 2017

  • ‘The Relationship between Tax Treaties & the Multilateral Instrument: Compatibility Clauses in the Multilateral Instrument’ (with Pasquale Pistone), Viennese Symposium on International Tax Law, Vienna, Austria, June 26, 2017

  •  ‘Recent case law on the role of the OECD model convention and the
    OECD commentaries in the interpretation of tax treaties’ (with Stephanie Zolles), The Practice of Double Tax Treaties in Case Studies – Senior level course, Vienna, Austria (2017-present)

  •  ‘Designing an inclusive and equitable model for International Tax Arbitration: An Indian perspective’ (with Shreya Rao), 4th meeting of the Vienna Multi-Stakeholder Group on Improving Cross-border Dispute Resolution, Vienna, Austria, May 8-9, 2017

  • ‘The impact of BEPS on tax systems in developing economies – The example of India’, Serbian Fiscal Society Young IFA Network Seminar, Belgrade, Serbia, December 5, 2016

  •  ‘India looks abroad: Analyzing structures for PE Exits and Tapping Global Capital Markets for Indian Companies’, Round Table + Webinar, Nishith Desai Associates Mumbai, India, November 27, 2014

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Selected List of Academic Publications

  • Book Chapters

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  1. Sriram Govind/ Jérôme Monsenego, Multilateralism in Dispute Resolution: Some Thoughts on the OECD Multilateral Instrument and the EU Dispute Resolution Directive in Brokelind/Dourado/Pistone/Weber (eds.), ‘Tax Multilateralism’, IBFD, forthcoming

  2. Sriram Govind, National Report: India, in Lang/Pistone/Rust/Schuch/Staringer (eds.), ‘Tax Treaty Arbitration’, IBFD, forthcoming

  3. Sriram Govind, National Report: India, in Lang/Pistone/Rust/Schuch/Staringer (eds.), ‘Implementing Key BEPS Actions: Where do we stand?’, IBFD, forthcoming

  4. Sriram Govind, Unilateralism in taxing the digitalised economy: Comparing the EU Digital Services Tax Proposal and the Indian Equalisation Levy in Pistone/Weber (eds.), ‘Taxing the Digital Economy’, IBFD, 2019, 161

  5. Sriram Govind, Personal Scope of the Mutual Agreement Procedure and Arbitration Provisions and the Mutual Assistance Provisions, Lang/Pistone/Rust/Schuch/Staringer (eds.), ‘Tax Treaty Entitlement’, IBFD, 2019, 253

  6. Sriram Govind/Stephanie Zolles, The Anti-Tax Avoidance Directive, in Lang/Pistone/Schuch/Staringer (eds.), ‘Introduction to European Tax Law on Direct Taxation’, 5th edition, Linde, 2018, 217

  7. Sriram Govind/Pasquale Pistone, The Relationship between Tax Treaties and the Multilateral Instrument: Compatibility Clauses in the Multilateral Instrument, in Lang/Pistone/Rust/Schuch/Staringer (eds.), ‘The OECD Multilateral Instrument for Tax Treaties: Analysis and Effects’, Wolters Kluwer, 2018, 111

  8. Sriram Govind, The Relationship between Domestic Specific Anti-Avoidance Rules and Tax Treaties, in Seiler/Blum (eds.), ‘Preventing Treaty Abuse’, Linde, 2016, 535

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  • Articles in Journals

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  1. Sriram Govind/Ivan Lazarov, Carpet-bombing Tax Avoidance in Europe: Examining the Validity of the ATAD under EU Law, 47 Intertax 10, 2019

  2. Sriram Govind, The new face of international tax dispute resolution: Comparing the OECD Multilateral Instrument with the EU Dispute Resolution Directive, 26 EC Tax Review 6, 2018, 309-324

  3. Sriram Govind/Christina Dimitropoulou/Laura Turcan, Applying modern, disruptive technologies to improve the effectiveness of tax treaty dispute resolution, Parts 1 and 2, 46 Intertax 11 and 12, 2018

  4. Sriram Govind/Shreya Rao, Designing an Inclusive and Equitable Framework for Tax Treaty Dispute Resolution: An Indian Perspective, 46 Intertax 4, 2018, 313-338

  5. Sriram Govind/Nathalie Bravo/Rita Julien/Pedro G. Lindenberg Schoueri, Implementing Key BEPS Actions: Where do we stand?, 45 Intertax 12, 2017, 852

  6. Sriram Govind/Laura Turcan,Tax Dispute Resolution in the 21st century: A comparative study of existing bilateral and multilateral remedies, Derivatives & Financial Instruments, 2017 (Volume 19), No. 5

  7. Sriram Govind, India and its Tryst with Subjective Rules: An Analysis of the Recent Place of Effective Management Guidance, Asia-Pacific Tax Bulletin, 2017 (Volume 23), No. 3 (online)

  8. Sriram Govind/Laura Turcan,The Changing Contours of Dispute Resolution in the International Tax World: Comparing the OECD Multilateral Instrument and the Proposed EU Arbitration Directive, Bulletin for International Taxation, 2017 (Volume 71), No. 3/4 (Online edition)

  9. Sriram Govind/Shreya Rao, Taxation of E-commerce in India, International Taxation, 2015 (Vol. 13), Issue 2, 118

  10. Sriram Govind/Samira Varanasi, Dispute Resolution in Tax Matters: An India-UK Comparative Perspective (with Samira Varanasi), Taxmann International Taxation, 2013 (Volume 9), Issue 3, 313

  11. Sriram Govind, The Propriety of the Force of Attraction Rule in International Tax Jurisprudence, Tax Notes International, 2013 (Volume 70), No. 9. 884

  12. Sriram Govind, The International Tax Treatment of Cross-Border Services, Bulletin for International Taxation, 2012 (Volume 66), No. 1 (Online edition)

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