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Dr Christiana HJI Panayi, BA BCL PhD

Senior Lecturer in Tax Law

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

Profile

Christiana HJI Panayi

Christiana is a Senior Lecturer 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 and has recently received a grant to conduct research for the Singapore Management University. Since 2012, she is a visiting professor at Sorbonne University (Ecole de droit de la Sorbonne, Université Paris 1).

In March 2015, Christiana was appointed to the European Commission’s Joint Transfer Pricing Forum (JTPF). The JTPF is a very prestigious body which assists and advises the European Commission on transfer pricing tax matters. The JTPF meets in Brussels on a quarterly basis.

Christiana has published extensively in the area of EU and International Tax Law and is considered a leading expert in her field. Her SSRN submissions often reach the top ten of their categories and are widely cited. 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 is the first book to be published in the area and has received excellent reviews. Christiana’s latest book, entitled Advanced Issues in International and European Tax Law is being published by Hart Publishing.

Christiana speaks regularly at tax conferences and teaches abroad. She has lectured at New York University, the University of Cambridge, Boston College, 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 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 studied at Oxford University for the BA in Jurisprudence and for the BCL. She also has a PhD from the London School of Economics. She is a solicitor of England & Wales and an advocate of the Cyprus Supreme Court. Before joining Queen Mary, Christiana worked for Allen & Overy LLP. Christiana is also a member of the Law Society of England & Wales, and the Cyprus Bar Association.

She is also a member of the BEPS Monitoring Group, a member of the OECD’s International Network of Tax Research, 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 the University College Dublin.

Teaching

Postgraduate teaching:

Research

Research interests:

Christiana’s research interests are in the area of European Union tax law, international tax law and corporate governance. She also has an interest in international treaty law and EU state aid law. Christiana is one of the leading researchers on the Common Consolidate Corporate Tax Base.

Her latest research is encapsulated in her monograph entitled Advanced Issues in International and European Tax Law. In this monograph, topics such as international tax avoidance, corporate social responsibility, good tax governance, harmful tax competition, state aid, tax treaty abuse and the Financial Transaction Tax are considered. The OECD/G20 project on Base Erosion and Profit Shifting (BEPS) features prominently and its interaction with the European Union’s Action Plan to strengthen the fight against tax fraud and tax evasion is considered.

Research Projects

The Singapore Management University - Tax Academy Centre for Excellence in Taxation (SMU – TA CET)  has commissioned Christiana HJI Panayi to do research on Exchange of Information, the New Common Reporting Standard and the Singapore/Asian perspective. The SMU-TA CET is a tax research centre set up by the Tax Academy in collaboration with the Singapore Management University and with the strong support of IRAS. It is the first centre in Singapore that is dedicated to research on international taxation with particular focus on Asian economies and tax systems.

Also, Christiana has been selected to participate in the European Commission’s Study on Aggressive Tax Planning which requires contributions from the 28 Member States. She and Joy Svasti-Salee will be in charge of the UK output and Christiana will also be in charge of the Cyprus output.

Publications

Christiana HJI Panayi's SSRN page

Books

  1. Double Taxation, Tax Treaties, Treaty Shopping and the European Community, Kluwer Law International, EUCOTAX Series 2007; ISBN/ISSN 9041126589
  2. The Common Consolidated Corporate Tax Base and the UK, Institute for Fiscal Studies, 2011; ISBN 978-1-903274-57-6
  3. European Union Corporate Tax Law (Cambridge University Press); ISBN: 9781107018990 (pp.1-416, excluding preliminaries)
  4. Advanced Issues in International and European Tax Law (Hart Publishing, forthcoming)

Chapters in Books

  1. “European Tax Law: Legislation and Political Initiatives", in Gore-Browne on EU Company Law (Jordan Publishing); ISBN: 0853084009
  2. European Community Tax Law and Companies: Principles of the European Court of Justice”, in Gore-Browne on EU Company Law (Jordan Publishing); ISBN: 0853084009
  3. “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)
  4. “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
  5. “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
  6. “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)
  7. “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
  8. “Cyprus Tax Treaty Dispute Resolution”, in Resolving Tax Treaty Disputes: A Global Analysis (Cambridge University Press, 2014) – forthcoming

Journal Articles

  1. “Open Skies for European Tax?”, [2003] British Tax Review 189-202 (Sweet & Maxwell); ISSN: 0007-1870
  2. “Limitation on Benefits and State Aid”, 44 [2004] European Taxation 83-98 (IBFD Publications); ISSN: 0014-3138
  3. “State Aid and Tax: The Third Way?”, 32 [2004] Intertax 287-311 (Kluwer Law International); ISSN: 0165-2826
  4. “Ships and Taxes: Does the Case of Commission v. Netherlands have Tax Implications?”, 45 [2005] European Taxation 97-102; ISSN: 0014-3138
  5. “Family Office: Wealth Management in the 21st Century”, Trusts and Estates Law & Tax Journal, May 2005; ISSN: 1743-5501
  6. “Agency Permanent Establishments in Securitisation Transactions”, 33 [2005] Intertax 286-296; ISSN: 0165-2826
  7. “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
  8. “Treaty-shopping and other tax arbitrage opportunities in the European Union: A Reassessment – Part 1”, 46 [2006] European Taxation 104-111; ISSN: 0014-3138
  9. “Treaty-shopping and other tax arbitrage opportunities in the European Union: A Reassessment – Part 2”, 46 [2006] European Taxation 139-155; ISSN: 0014-3138
  10. “Exploring the Open Skies: EC-incompatible treaties between Member States and Third Countries”, [2006] Yearbook of European Law 315; ISBN: 0263-3264
  11. “Multistate Cumulative Tax Burdens and Reliefs in the European Community - Lessons from the United States”, 47 [2007] European Taxation 15; ISSN: 0014-3138
  12. “The Protection of Third-Country Rights in Recent EC Case Law”, Tax Notes International, 19 February 2007; ISSN: 1058-3971
  13. “The Effect of Community Law on Pre-Accession Tax Treaties”, 16/3 [2007] EC Tax Review 120; ISSN: 0928-2750
  14. “Thin Capitalisation GLO et al. – a thinly concealed agenda?”, 35 [2007] Intertax 298; ISSN: 0165-2826
  15. “Tax Treaty Law and Community Law – Some Recent Developments”, [2007] 3 EC Tax Journal 10; ISSN: 1350-1089
  16. “Recent Developments to the OECD Model Tax Treaty and EC Law”, 47 [2007] European Taxation 452; ISSN: 0014-3138
  17. “The Common Consolidated Corporate Tax Base: Issues for Third Countries and Member States opting out”, 48 [2008] European Taxation 114; ISSN: 0014-3138
  18. “The Fundamental Freedoms and Third Countries”, 48 [2008] European Taxation 571; ISSN: 0014-3138
  19. “The proposed amendments to the Savings Directive”, 49 [2009] European Taxation 179
  20. “Corporate Mobility under Private International Law and European Community Law: Debunking Some Myths”, [2009] Yearbook of European Law 124-176
  21. “Tax Treaties post-Damseaux”, [2009] Tax Journal, 14 September 2009, 9
  22. “Corporate mobility in the European Union and Exit Taxes”, [2009] Bulletin for International Taxation 459
  23. “Rethinking Treaty-Shopping: Lessons for the European Union”, [2010] International Taxation, volume 2, issue 1, p.15
  24. “Reverse Subsidiarity and Cross-border loss relief: Can Member States be left to their own devices?”, 55 [2010] 3 British Tax Review 267-301
  25. “Exit taxation as an obstacle to corporate emigration from the spectre of EU tax law”, [2011] Cambridge Yearbook of European Legal Studies 245
  26. “Anti-abuse rules within the CCCTB”, [2012] 4/5 Bulletin for International Taxation 256
  27. “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
  28. “The Taxation of Permanent Establishment in EU Tax Law: Selected Issues”, [2013] 4/5 Bulletin for International Taxation pp.226-237; ISSN: 0007-4624
  29. 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
  30. “The EU’s Financial Transaction Tax, Enhanced Cooperation and the UK’s challenge” [2013] 8 European Taxation pp.358-367; ISSN: 0014-3138
  31. “Is Aggressive Tax Planning Socially Irresponsible?” [2015] 10 Intertax 543-557

Peer-Reviewed Articles

  1. “Open Skies for European Tax?”, [2003] British Tax Review 189-202 (Sweet & Maxwell); ISSN: 0007-1870
  2. “Agency Permanent Establishments in Securitisation Transactions”, 33 [2005] Intertax 286-296; ISSN: 0165-2826
  3. “Exploring the Open Skies: EC-incompatible treaties between Member States and Third Countries”, [2006] Yearbook of European Law 315; ISBN: 0263-3264
  4. “Corporate Mobility under Private International Law and European Community Law: Debunking Some Myths”, [2009] Yearbook of European Law 124-176
  5. “Reverse Subsidiarity and Cross-border loss relief: Can Member States be left to their own devices?”, 55 [2010] 3 British Tax Review 267-301
  6. “Exit taxation as an obstacle to corporate emigration from the spectre of EU tax law”, [2011] Cambridge Yearbook of European Legal Studies 245
  7. “Is Aggressive Tax Planning Socially Irresponsible?” [2015] 10 Intertax 543-557

Book reviews

  1. (Publication Review) The Impact of Community Law on Tax Treaties: Issues and Solutions, [2004] British Tax Review 582-583
  2. (Publication Review) Free Movement of Capital, Income Taxation and Third Countries: Four Selected Issues, [2008] British Tax Review 413
  3. (Publication Review) European State Aid Law and Policy, [2009] 4 British Tax Review 486-488;
  4. (Publication Review) Legal Remedies in European Tax Law, [2010] 4 British Tax Review 354-356
  5. (Publication Review) Traditional and Alternative Routes to European Tax Integration, [2011] 3 British Tax Review 356-358
  6. (Publication Review) EC law and the Sovereignty of the Member States in Direct Taxation, [2011] British Tax Review pp.716-717
  7. (Publication Review) European Tax Law – Terra & Wattel, [2012] 5 British Tax Review pp.681-682
  8. (Publication Review) Prohibition of Abuse of Law, [2012] 5 British Tax Review pp.682-683
  9. (Publication Review) Introduction to European Tax Law: Direct Taxation, [2013] 3 British Tax Review pp.355-356
  10. (Publication Review) Taxation of Intercompany Dividends under Tax Treaties and EU law, [2013] British Tax Review (forthcoming)
  11. (Publication Review) The Missing Keystone of Income Tax Treaties, [2013] British Tax Review (forthcoming)
  12. (Publication Review) Human Rights and Taxation in Europe and the World [2014] 4 British Tax Review pp. 500-502
  13. (Publication Review) The Structure and Organization of EU Law in the Field of Direct Taxes [2014] 4 British Tax Review pp.502-50
  14. (Publication Review) Fixing US International Taxation [2014] 4 British Tax Review pp.499-500

PhD 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:

  • 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”.

Public engagement

Professional activities and outreach.

Public speaking engagements

2015

  • 20 April, speaker at the Athens Tax Forum, organised by the American Hellenic Chamber of Commerce
  • 7 April, lectured LLM students at the University of Lausanne, on the topic of mergers and reorganisations
  • 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.

Membership to Professional Bodies and Learned Societies

  • Solicitor of the Law Society of England & Wales
  • Advocate of the Cyprus Supreme Court
  • Member of the International Network of Tax Research of the OECD (Steering Group committee member)
  • Research fellow of the Tax Law Review Committee of the Institute for Fiscal Studies
  • Member of the European Association of Tax Law Professors * Peer Reviewer for the European Science Foundation
  • Examiner of the Chartered Institute of Taxation
  • Member of the Examination Sub-Committee of the ADIT (Advanced Diploma in International Taxation)
  • Member of the BEPS Monitoring Group (BMG)
  • Member of the EU Joint Transfer Pricing Forum.

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