Błażej Kuźniacki, Author at Kluwer International Tax Blog

By Błażej Kuźniacki

PwC Netherlands, Lazarski University and Singapore Management University

Błażej Kuźniacki is an Associate Professor at the Lazarski University (Warsaw), Research Associate at the Centre for AI and Data Governance at the Singapore Management University, and an immediate ex-Assistant Professor at the University of Amsterdam focusing on explainable AI in tax law. He also is Advisor at PwC Global Tax Policy team, Senior Manager at the International Tax Services at PwC Netherlands (Amsterdam office) and attorney-at-law (Warsaw Bar Association). Holding a PhD from the University of Oslo (Norway, since 2017) and a habilitation from the Lazarski University (Poland, since 2023), Błażej is the author of around 100 publications with national and global coverage, including award-winning articles in renowned journals and four monographs. Błażej speaks frequently on international and EU tax law, investor-State dispute settlement (ISDS) tax related cases and eXplainable AI next to his practice in these fields, including expert witness’s opinions and strategic advice.

BEPS, MLI, OECD

Active Business Test in the MLI’s LOB rule: The First Subtest

Błażej Kuźniacki ( PwC Netherlands, Lazarski University and Singapore Management University)/May 17, 2018May 17, 2018 /Leave a comment

Introduction This is the first part of the input regarding the MLI’s LOB. It addresses the active conduct of a business, which constitutes the first subtest under the MLI’s LOB rule. The second part, in turn, will draw attention to the second and the third subtests, i.e. the concept of income emanating from or being…

BEPS, OECD, Tax Policy

Untangling the PPT’s burden of proof

Błażej Kuźniacki ( PwC Netherlands, Lazarski University and Singapore Management University)/January 22, 2018January 19, 2018 /Leave a comment

At the current stage, it is difficult to predict a potential application of the principal purposes test (PPT) and its outcome since it has not entered into force in the 72 Signatories of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). However, assuming that this happens…