Stojący, łysy mężczyzna z brodą w granatowym garniturze na szarym tle

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dr hab. Błażej Kuźniacki, prof UŁa



Professor of law at Lazarski University in Warsaw and a Senior Research Affiliate in Singapore Management University, holding a PhD from the University of Oslo and habilitation from Lazarski University. The author of over 150 publications, including several books. An attorney at law focusing on strategic tax advice and dispute prevention and resolution in cross border tax related cases. Expert and witness expert in cross border tax related cases.

Professional Profile

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  • 2023 The Hague Academy of International Law
  • 2022 Habilitation (Associate Professorship) in Law, Lazarski University. The habilitation thesis title: “Beneficial Ownership in International Taxation”
  • 2017 PhD in law, University of Oslo. The PhD thesis title: “Controlled Foreign Companies and Tax Avoidance. International and Comparative Perspectives with Specific Reference to Polish Tax and Constitutional Law, EU Law and Tax Treaties”. Thesis supervisor: Professor Doctor Frederik Zimmer
  • 2010 MA in Law (Frist class), Faculty of Law and Administration, Nicolaus Copernicus University with honors of the best student and the best graduate
  • 2010 Faculty of Law, University of Bergen, Erasmus student exchange programme
  • 2009 MA in European Law (First class), Faculty of Law and Administration, Nicolaus Copernicus University

Research focus

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international tax law, investment treaty arbitration in tax related cases, tax and international law and AI in the public domain. 

Research Experience

  • Associate Professor in Law, Lazarski University, since 7.2023
  • Research Assistant Professor in Law, Lazarski University, 11.2021-6.2023
  • Research Assistant Professor in International Tax Law, University of Amsterdam, 11.2021-5.2023
  • External Senior Research Fellow in International Tax Law (part time), University of Amsterdam, 5.2019–10.2021
  • Post-Doctoral Research Fellow in International Tax Law (full time), Singapore Management University, 4.2017-3.2018
  • Doctoral Research Fellow in International Tax Law (full time), University of Oslo, 9.2012-6.2016

Professional Appointments

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  • Reviewer at “Journal of World Investment & Trade”,  “World Tax Journal”,  Polish Yearbook of International Law,   “Intertax”, “Accounting, Economics, and Law: A Convivium”
  • Acting as the expert witness in a cross border tax case in front of the Dutch court
  • Contributing to the expert witness report in a pending investment treaty arbitration in a European renewable energy case under the United Nations Commission on International Trade Law (UNCITRAL) Rules 1976 – proceedings commenced pursuant to relevant provisions of the Energy Charter Treaty (ECT) and the provisions of the three bilateral investment treaties (BITs) among the EU Member States
  • Contributing the tax expert report in a pending high profile case concerning cross border tax controversy between one the largest multinationals and the Indian tax authorities in front of the Supreme Court of India (the Assessing Officer Circle (International Taxation) New Delhi v. Nestle and others case, the judgment of 19 October 2023)
  • Acting as the expert and providing second opinion in several high profile national and international cases and  tax controversies regarding the Polish and foreign private and corporate taxpayers
  • Acting as the Competent Authority for the Ministry of Finance in Poland for the purposes of Mutual Agreement Procedures under the double tax treaties ratified by Poland in 2018-2019
  • Supervising and co-drafting legally binding clarifications to the Polish Investment Zone regime introduced to the Polish tax law as of 10 May 2018 and legally binding general tax interpretation of 25 October 2019
  • Interpretative and legislative supervision over the application of tax exemptions in income taxes granted under the permission to conduct business activities in special economic zones and on the basis on decisions supporting new investments in Poland

Publications

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* Over 150 publications – below is just a list of circa 10% of them (15 selected) (for the full list see the full CV here)

  1. “Potential U.S. Defense Measures Against the UTPR and DSTs In the Light of International Law”, Tax Notes International, May 5, 2025
  2. “Prohibition of Abuse and Beneficial Ownership: Disentanglement via a Principle-Based Approach in EU Tax Law (and Beyond)”, 79 Bulletin for International Taxation 4 (2025) [Co-author Juliane Kokott]
  3. “VCLT and the Peaceful Coexistence of Tax and Investment Treaties: A Case Study of Limited MFN Clauses and the FET Standard”, 17 World Tax Journal 1/2025 [Co-author Stef van Weeghel]
  4. “Exploring explainable AI in the tax domain”, Artificial Intelligence and Law (2024) [Co-authors:  Łukasz Górski, Marco Almada, Kamil Tyliński, Madalena Calvo, Pablo Matias Asnaghi, Luciano Almada, Hilario Iñiguez, Fernando Rubianes, Octavio Pera & Juan Ignacio Nigrelli]
  5. “The Compatibility of the Substance Over Form Doctrine with Tax and Investment Treaties – a Case Study of Lone Star v. the Republic of Korea”, 39 The ICSID Review—Foreign Investment Law Journal 1 (2024)
  6. “Pillar 2 and International Investment Agreements: “QDMMT Payable” Seals Internationally Wrongful Act”, Tax Notes International (9 October 2023)
  7. “European Union Law and Global Investment Regime: Unshell Proposal as a Next (Mis)Step of the EU Against Investment Treaty Arbitration?”, Intertax 11/2022
  8. “Beneficial Ownership in International Taxation”, Elgar Edward Publishing (August 2022)
  9. “X-GmbH v Finanzamt Stuttgart — Körperschaften: Abuse of Tax Law and Exchange of Tax Information in EU law”, Modern Law Review (2/2022)
  10. “Implementation and Application of the LOB Clause in BEPS Action 6/MLI: Legal and Pragmatic Challenges”, in A. P. Dourado (ed.), International and EU Tax Multilateralism: Challenges Raised by the MLI, IBFD 2020
  11. “Chapter 6: The GAAR (Article 6 ATAD)”, in W. Haslehner, G. W. Kofler, A. Rust (eds.), A Guide to the Anti-Tax Avoidance Directive, Edward Elgar Tax Practice Series (2020).
  12. “Controlled Foreign Companies and Tax Avoidance. International and Comparative Perspectives with Specific Reference to Polish Tax and Constitutional Law, EU Law and Tax Treaties”, C.H. Beck: Warsaw (2020).
  13. “The C.J.E.U. Case Law Relevant to the General Anti-Avoidance Rule (G.A.A.R.) Under the Anti-Tax Avoidance Directive (A.T.A.D.)”, 4 University of Bologna Law Review 2/2019.
  14. “The Principal Purpose Test (PPT) in BEPS Action 6/MLI: Exploring Challenges arising from its Legal Implementation and Practical Application”, World Tax Journal 2/2018
  15. “Tax Avoidance through Controlled Foreign Companies under European Union Law with Specific Reference to Poland” in Accounting, Economics, and Law: A Convivium 1/2017.

Research Experience

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  • Since 4.2025 – Senior Research Affiliate at the Singapore Management University – Centre for Digital Law
  • Since 7.2023 – Associate Professor at the Faculty of Law and Administration, Łazarski University, Warsaw, Poland
  • Since 7.2022 – Senior Manager in Global Tax Policy & International Tax Services at the PwC Netherlands
  • Since 1.2022 – Advisor and Member of the Steering Group at the PwC Global Tax Policy
  • Since 3.2017 – External lecturer in international tax law at the Brazilian Institute of Tax Law (IBDT), São Paulo
  • 7.2023-4.2025 – Research Affiliate at the Singapore Management University – Centre for Artificial Intelligence and Data Governance
  • 7.2020-6.2023 – Research Assistant Professor at the Faculty of Law and Administration, Łazarski University, Warsaw, Poland
  • 11.2021–5.2023 – Assistant Professor at the Amsterdam Centre for Tax law, Faculty of Law, University of Amsterdam
  • 6.2017–7.2018 – External lecturer in international and European tax law at the GREIT Summer Course, University of Lisbon
  • 6.2020–7.2022 – Deputy Director - Strategic Tax Advice and Dispute Resolution, PwC, Poland
  • 5.2019–10.2021 – External Senior Research Fellow at the Amsterdam Centre for Tax Law, University of Amsterdam
  • 5.2019–7.2020 – Member of: the Audit Committee and the Supervisory Board at the Bank Pocztowy
  • 12.2018–12.2019 – Deputy Director at Poland’s Ministry of Finance (Poland), Income Tax Department
  • 7–12.2018 – Counsel for the ministry at Poland’s Ministry of Finance (Poland), Tax System Department
  • 4.2017–4.2018 – Post-doctorate Research Fellow at the Singapore Management University – Tax Academy Centre for Excellence in Taxation
  • 5.2016–11.2017 – Of Counsel at the law firm PATH LLP
  • 9.2012–6.2016 – PhD Research Fellow in Tax Law, Department of Public and International Law, University of Oslo
  • 3–6.2015 – Visiting Research Scholar at the Institute for Austrian and International Tax Law, Vienna (WU), Austria

Conferences

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* Over 150 conferences – below is just a list of circa 6.6% of them (10 selected) in which I was a speaker or a key note speaker (for the full list see the full CV here)

  1. 20-21.03.2025, Budapest, International Fiscal Association (IFA) Europe  Conference “Tax competition in Europe in 2025”, the speaker (Panel 5) “Tax competition after Pillar 2 with a regional focus – round table discussion”
  2. 11.12.2024, Warsaw, Keynote speaker, the title of the presentation “7 main errors in the interpretation of the Supreme Administrative Court in cases regarding beneficial ownership (BO) – causes and effects” at the scientific conference “Dilemmas and challenges in the field of withholding tax in the context of Poland's competitiveness as an investment jurisdiction” held at the Warsaw School of Economics in Poland
  3. 9-10.12.2024, Brussels, Speaker, the title of the presentation “X BV vs Lexel AB and the concept of abuse in the case of intra-group loans” during the EU Direct Tax Group (EUDTG) Conference of PwC “Ready to talk EU tax when you are”
  4. 27-31.10.2024, Cape Town, Speaker at The 76th Congress of the International Fiscal Association, Seminar H: “Recent Developments in international taxation: Theme 3 – Beneficial ownership”
  5. 27.09.2024, Copenhagen, Speaker on “The Relationship Between the GAAR and Transfer Pricing (TP)” at the 7th annual Copenhagen conference on EU tax law “EU Tax Law in a Digital World and Transfer Pricing – Navigating a Dynamic Landscape”
  6. 17.04.2024, Oslo, Keynote speaker on “Beneficial Ownership in International Taxation” at the International Fiscal Association – Norwegian Branch conference
  7. 12.03.2024, Curaçao, The keynote speaker at the 1st Lecture of IFA Branch Curaçao-Aruba-Sint Maarten on “The value and limits of eXplainable AI for tax”
  8. 22-26.10.2023, Cancún, Mexico, Panelist and speaker at the IFA/EU seminar with focus on “The EU Law and   Investment Treaty Arbitration in Tax Relates Cases” at the IFA Global Congress
  9. 10.03.2023, Amsterdam, the Netherlands, Co-Speaker together with Marco Almada on „Towards eXplainable Artificial Intelligence (XAI) in Tax Law: The Need for a Minimum Legal Standard” during the ACTL-CPT international scientific conference „Towards eXplainable Artificial Intelligence (XAI) in Taxation: The Future of Good Tax Governance”
  10. 9-10.2019, Geneva, Speaker, topic “Real Time Tax Compliance and AI Applications: Identifying the Legal, Regulatory and Cultural Constraints” at the Global Tax Conference “Tax Compliance: Exploiting the Potential of AI, Robotics and Data Analytics” at the Universite de Geneve, 9-10 October 2019, Digital Economy Taxation Network

Awards and Honors/Grants and Fellowships

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  • The 2023 IFA Mitchell B. Carroll Prize for publication of the book “Beneficial Ownership in International Taxation”
  • The 2016 IFA President YIN Scientific Award for the publication of article “The Need to Avoid Double Economic Taxation Triggered by CFC Rules under Tax Treaties, and the Way to Achieve it” at the Intertax 2015, No. 12
  • The 2016 Norway Branch YIN Scientific Award for the publication “Strengthening CFC Rules in a Compatible Way with EU Law under BEPS Action 3 in Light of the European Commission’s Proposal – A Critical Evaluation”, Zürich: Schulthess, 2016.
  • The best tax law article in tax law published in Norway in 2014: “EEA Exemption from Norwegian CFC rules” at the “Skatterett” 2014, No. 3 (nomination for the price “The Article of the Year” of the Universitetsforlagets)
  • An honorable mention of the Jury of the IFA President YIN Scientific Award 2014 for the article “The Service PE Concept in light of the Poland-Norway Income Tax Treaty (2009)” at the European Taxation 2014, No. 1
  • IFA National Reporter of the Polish Branch at the IFA Congress in Mumbai 2014 for the Subject II: “Qualification of taxable entities and treaty protection”
  • Title of the Faculty of Law and Administration Best Graduate, awarded in 2010 by Nicolaus Copernicus University in Torun
  • Rector’s Award for Outstanding Academic Achievements in the Field of Tax Law and Popularization of the Nicolaus Copernicus University’s Name, awarded in 2010
  • Title of the best student awarded in 2009 by the Faculty of Law and Administration, Nicolaus Copernicus University
  • Second award won at the XIth National Science Conference organized by The Centre of Tax Documentation and Studies in Lodz
  • Third place won in the XIIIth Local Oratory Contest, 2009, Torun

Grants and Fellowships (Scholarships)

  • University of Notre Dame (Indianapolis, IN, US) – IBM Technology Ethics Lab: Grant for the period 1 March 2022 to 31 December 2023 to realise the interdisciplinary research project “Exploring Local Post-Hoc Explanation Methods in Tax-Related AI Systems”
  • Singapore Management University – Tax Academy Centre for Excellence in Taxation:  Post-doctorate research fellowship for the period of 1 April 2017 to 31 March 2018 to realise the research project “Singapore’s Tax Attractiveness in Light of the OECD’s BEPS’s Action 6 – Prevention of Tax Treaty Abuse”
  • University of Oslo,  Department of Public and International Law: PhD research fellowship in international and comparative tax law for the period of 1 September 2012 to 30 June 2016 to conduct the research on “International Tax Avoidance from Domestic, Comparative and International Perspectives: Specific Reference to Controlled Foreign Companies”
  • Vienna University of Economics and Business, the Institute for Austrian and International Tax Law: Visiting Research Scholar Fellowship from 1 March 2015 to 30 June 2015 to conduct research on “Prevention of Tax Avoidance Through the Use of Controlled Foreign Company Rules”
  • University of Lodz,  the Centre of Tax Documentation and Studies:  Visiting Research Scholar Fellowship for the period of 1 October 2013 to 28 February 2014 to conduct research on “Constitutionality of Anti-Tax Avoidance Rules: Focus on Controlled Foreign Company Rules”
  • Scholarship for Outstanding Young Scientist in Poland (2021-2024)
  • Scholarship for the most talented young scholars in Poland granted by the Foundation for Polish Science (FNP) (2015)
  • Ministry of Science and Higher Education Scholarship awarded for academic achievements for the academic year 2009/2010
  • Scholarships for academic achievements in all academic years of Law Studies and European Law Studies (2005-2010)

Teaching Experience

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  • Międzynarodowe studia licencjackie: „Tax Law in International Perspective” na Uczelni Łazarskiego
  • Międzynarodowe studia specjalistycznego formatu Legum Magister (LLM) (wybrane wykłady): „Beneficial Ownership and Limitation on Benefits” i „Tax Treaty Abuse” – Advanced LLM in International Tax Law na Uniwersytecie w Amsterdamie
  • Międzynarodowe studia podyplomowe (wybrane wykłady):
    • „Beneficial Owner in Withholding Taxation - Allocation of Income or Prevention of Abuse of International and EU Tax Law?”  oraz „ Introduction to International Investment Treaty Arbitration from the Perspective of Protection of Investments Against Abuse of Fiscal Power" w Szkole Głównej Handlowej w Warszawie.
    • „Do International Investment Agreements Protect Against Pillar Two and Digital Service Taxes?-Introduction” na Kyoto University International Law Study Group Kokusaiho Kenkyukai (国際法研究会).
    • „Legal challenges to global minimum tax under international law” w Instituto Brasileiro de Direito Tributário (IBDT), São Paulo
    • “Is the UTPR compatible with non-discrimination provision under tax treaties?” Seminario “Actualidad Tributaria Internacional” Programa de Magíster en Derecho Tributario de la Universidad de Concepción, Chile