Noemi Strotkemper has been awarded the Mitchell B. Carroll Prize

25 January 2019

The International Fiscal Association has awarded the prestigious Mitchell B. Carroll Prize to Noemi Strotkemper, member of the International Max Planck Research School for Successful Dispute Resolution in International Law (IMPRS-SDR), for her dissertation.

The Prize was awarded during the 72nd Congress of the International Fiscal Association 2-6 September 2018 in Seoul, Korea. It recognizes original work making a theoretical or practical contribution to the study of the effects of taxation. The selecting jury consisted of five members appointed by the Executive Committee of the International Fiscal Association from among the IFA membership upon recommendation by the Permanent Scientific Committee.

The thesis, entitled "Das Spannungsverhältnis zwischen Schiedsverfahren in Steuersachen und einem internationalen Steuergerichtshof - Möglichkeiten zur Verbesserung der Streitbeilegung im Internationalen Steuerrecht" / "Improving Dispute Resolution in International Tax Law - Tensions between Tax Treaty Arbitration and an International Tax Tribunal", was written under the supervision of Prof. Dr. Ekkehart Reimer at Heidelberg University within the IMPRS-SDR.

In her dissertation, Noemi Strotkemper unveils and examines the shortcomings in the dispute settlement regimes of double tax treaties, which seek to avoid double taxation in cross-border cases on the basis of intergovernmental agreements by the competent authorities. Having assessed the efficiency of the current regime of mutual agreement and arbitration proceedings, she analyses the various characteristics of conflicts of interpretation or application on the one hand, and of transfer pricing conflicts on the other hand. Building on her findings and seeking for more tax certainty, she devises customized dispute resolution mechanisms for the different types of conflicts including a draft multilateral tax treaty for dispute resolution.

Noemi Strotkemper's thesis was published in 2017 by Nomos Publishing in the Series Successful Dispute Resolution. It has also been awarded the prize "International Tax Law" by the German Federal Chamber of Tax Consultants (Bundessteuerberaterkammer) (2018) and the Matthias-Erzberger-Wissenschaftspreis of the Steuerberaterkammer Nordbaden (2017).