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Dr Christiana HJI Panayi, BA BCL PhD

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Senior Lecturer in Tax Law

email: c.hji-panayi@qmul.ac.uk
Phone: +44 (0)20 7882 8105
Fax: +44 (0)20 7882 8101

Christiana is a senior lecturer in Tax Law at Queen Mary, University of London. She teaches on the EU Tax Law, International Tax Law, Taxation Principles and Concepts, and UK Business Taxation courses of the LLM Programme. Christiana is Visiting Professor in Sorbonne, where she teaches European Union Tax Law.

Christiana is also a researcher at the Institute for Fiscal Studies. Her report 'The Common Consolidated Corporate Tax Base and the UK tax system' examines the effect of the Common Consolidated Corporate Tax Base on the UK tax system for the Tax Law Review Committee and was published in 2011.

Furthermore, Christiana is an external examiner for the University of Dundee and University College Dublin.

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. Her doctoral thesis entitled "Double Taxation, Tax Treaties, Treaty Shopping and the European Community" won the 2007 tax thesis competition conducted jointly by the European Commission and the European Association of Tax Professors. The thesis was also published by Kluwer Law, EUCOTAX Series in 2007.

Christiana is a solicitor of England & Wales and an advocate of the Cyprus Supreme Court. Before joining Queen Mary, she worked for Allen & Overy. Christiana is also a member of the Law Society and the Cyprus Bar Association.

Christiana has published extensively in the area of EU and International Tax Law. She speaks regularly at tax conferences and teaches abroad. In 2011, Christiana lectured at NYU, Cambridge University and Boston College. In 2012, she presented a workshop on the Common Consolidated Corporate Tax Law at the Cambridge Centre for Tax Law and in other various universities and organisations.

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 - 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 The CCCTB and Third Countries, (Linde, forthcoming)

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

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

Research interests:

Christiana’s research interests are in the area of European Union tax law, international tax law and taxation of corporate finance. She also has a keen interest in US and Cypriot tax law, international treaty law, state aid law and the external affairs of the European Union.

Christiana’s current research focus in on EU corporate tax law and the various legislative developments at EU level. She is also one of the leading researchers on the Common Consolidate Corporate Tax Base.

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