Robert Danon, Author at Kluwer International Tax Blog

By Robert Danon

Head of Tax Policy Center, University of Lausanne, Partner, DANON, Lausanne and Chairman of the Permanent Scientific Committee (PSC) of the International Fiscal Association (IFA)

Robert Danon is a Full Professor of Law at the University of Lausanne (Switzerland) where he heads its Tax Policy Center. He also co-leads the research platform of the University of Lausanne dedicated to the role of investment and commercial arbitration in tax disputes.
Robert Danon serves as the Chairman of the Permanent Scientific Committee (PSC) of the International Fiscal Association (IFA), the global tax association with around 13,000 members from 116 countries.

International Tax Law, MAP, OECD

The effectiveness of the Mutual Agreement Procedure and the global tax controversy landscape: some critical observations on current pressure areas and suggestions to improve the framework

Robert Danon (Head of Tax Policy Center, University of Lausanne, Partner, DANON, Lausanne and Chairman of the Permanent Scientific Committee (PSC) of the International Fiscal Association (IFA))/May 28, 2025May 28, 2025 /Leave a comment

Introduction On 22 May we delivered an opening address on the current practical challenges of dispute prevention and resolution at the International Tax Dispute Day organized in Singapore by the Tax Policy Center of the University of Lausanne and the Singapore Tax Academy. While acknowledging the progress made since the adoption of BEPS Action 14…

Dispute resolution, International Investment Agreements, UN Tax Convention, United Nations

The Override of International Investment Agreements by Double Taxation Conventions in the Latest UN Model Tax Convention: Critical comments

Prof. Dr. Robert J. Danon, University of Lausanne /DANON /Prof. Dr. Adolfo Martín Jiménez, University of Cádiz/AMJ ITC On 24-27 March 2025, the United Nations Committee of Experts on International Cooperation in Tax Matters (“UN Tax Committee”), in its 30th session, approved the latest changes to a new clause to be introduced into art. 25…

Abuse of rights, Beneficial ownership, Denmark, ECJ, Intertax, Principal purpose test, Switzerland

The Prohibition of Abuse of Rights after the ECJ Danish cases

Analysis of the ECJ judgments, reading by national courts, and impact on tax treaty practice Authors: Robert Danon,[1] Daniel Gutmann,[2] Margriet Lukkien,[3] Guglielmo Maisto,[4] Adolfo Martín Jiménez,[5] Benjamin Malek[6] (Forthcoming: Intertax, vol. 49, 2021, issue 6/7) Since they were delivered in 2019, the judgments of the ECJ in the Danish cases have been widely…

Abuse of law, Beneficial ownership, Dividends, EU law, EU/EEA, Switzerland, Withholding Taxes

Swiss Supreme Court Refers to the CJEU “Danish cases” in Outbound Dividend Case Involving the Swiss-EU Savings Agreement

Recently, national courts of several EU member States (notably France[1], Italy[2], the Netherlands[3] and Spain[4]) referred to the landmark judgments of the Court of Justice of the European Union (“CJEU”) in the so-called “Danish cases”.[5] On 20 April 2020, the Swiss Supreme Court gave its own interpretation of these judgments[6] in an outbound dividend case…