Robert Danon is tenured Professor of Law at the University of Lausanne (Switzerland) where he heads its Tax Policy Center. Next to his academic duties, Robert is a founding partner of Danon, an independent firm with a predominant focus on cross-border tax disputes and international arbitrations.
Robert is a member of several academic and professional organizations dealing with tax law. In particular, he currently serves as the Chairman of the Permanent Scientific Committee (PSC) of the International Fiscal Association (IFA).
Robert has practiced tax law for over twenty years and his expertise covers all areas of Swiss and international tax law. From an international standpoint, his expertise focuses on tax treaty law (including its interaction with investment law), transfer pricing, dispute resolution and, more broadly, public international law. His recent assignments have for example dealt with the issue of abuse in international tax law, the attribution of profits to permanent establishments, non-discrimination and most favored nation clauses (MFNs) as well as State responsibility for internationally wrongful acts.
Robert regularly serves as expert witness in international tax law in high profile arbitration cases, including commercial arbitrations or those involving non-tax agreements such as Bilateral Investment Treaties (BITs) or the Energy Charter Treaty (ECT).
Robert also advises governments and MNEs groups on reforms and corporate tax governance issues associated thereto. For instance, in 2015 he was requested by Switzerland’s Finance Minister to analyze the constitutionality of its corporate tax reform aimed at complying with the Organization for Economic Cooperation and Development (OECD) and European tax standards. He is regularly invited by the OECD to express his views on matters of international tax law. He has in particular done so on (i) beneficial ownership (2011), (ii) hybrid entities (2014), (iii) the attribution of profits to permanent establishments (2017) and (iv) the challenges raised by digitalization (2017-2019). Robert holds a PhD (“doctorat en droit”) in Law from the University of Geneva (“summa cum laude”) and an LL.M in International Taxation from the University of Leiden (the Netherlands) which he completed while fully involved in private practice.
- Professor of Law at the University of Lausanne and Director of its Tax Policy Center
- Chairman of the PSC of the IFA
- Member of the board of the Swiss IFA branch
- Member of the advisory board of several leading tax journals (inter alia Intertax and the International Tax Law Reports)
- The Principal Purpose Test Under the OECD and UN Model Tax Conventions: Impact for Taxpayers and Limits for States Under International Law in: M Buttani (editor), GAAR Treatise, Kluwer
- Foreword: Tax Treaty Interpretation after BEPS in: Bulletin for International Taxation, IBFD, special issue, 4-5 2020 (coauthor with W. Schön)
- The Principal Purposes Test (PPT) in Post BEPS Tax Treaty Law, It is a GAAR but just a GAAR! in: Bulletin for International Taxation, IBFD, special issue, 4-5 2020
- The beneficial ownership limitation in articles 10, 11 and 12 OECD MC and conduit companies in pre and post BEPS tax treaty policy – Do we (still) need it? in: G. Maisto, (editor), Contemporary Tax Issues, Amsterdam (IBFD)
- EU Fiscal Protectionism Versus Free Movement of Capital: The Case of the ATAD CFC Categorical Model, in P. Pistone (ed), European Tax Integration: Law, Policy and Politics, IBFD
- Can Tax Treaty Policy Save Us? The Case of the Digital Economy in Arnold B. J. (editor.) in Tax Treaties After the BEPS Project: A Tribute to Jacques Sasseville, Canadian Tax Foundation
- The BEPS Multilateral Instrument: General overview and focus on treaty abuse in IFF Forum für Steuerrecht 2017 (coauthor with Hugues Salomé)
A full list of publications is available here.