Błażej Kuźniacki

Błażej Kuźniacki is a tax practitioner with qualification as an attorney-at-law (Warsaw Bar Association), currently working at PwC Netherlands (Amsterdam office) with International Tax Services Team and the PwC Global Tax Policy Team. Błażej provides a strategic tax advice on international tax law and global tax policy. He also is an academic, holding positions of Professor of Law at the Lazarski University and Senior Research Affiliate at the Singapore Management University – Centre for Digital Law. Until 2023, he worked as Assistant Professor at the University of Amsterdam (Amsterdam Centre for Tax Law, ACTL). Holding a PhD from the University of Oslo (Norway, since 2017) and a habilitation from the Lazarski University (Poland, since 2023), Błażej is the award winning author of more than 150 scientific publications with national and global coverage, including four books. For the book “Beneficial Ownership in International Taxation” (2022), as the first Polish tax scholar, Błażej was awarded with the International Fiscal Association (IFA) Mitchell B. Carroll Prize in 2023. He speaks frequently on international tax law, investment tax related disputes and tax XAI (eXplainable AI) next to his practice in these fields, including expert witness’s opinions.

• Practice: tax controversy and dispute resolution, global tax policy, the interplay between taxation, general international law and specialized regimes of international law (esp. international investment law and international law of countermeasures). Expert before Polish and foreign courts and tribunals.
• Research: interpretation of (i) tax treaties, (ii) EU treaties and directives, and (iii) international investment agreements; (iv) abuse of tax law under domestic, EU and tax treaty law; (v) comparative tax law; (vi) taxation and international investment law; (vii) taxation and international law of countermeasures.
• Membership: International Fiscal Association (IFA); International Law Association (ILA); European Association of  Tax Law Professors (EATLP); European Federation for Investment Law and Arbitration (EFILA); International Association for Artificial Intelligence and Law (IAAIL).
• Additional Activities:
  • Acting as the expert and providing second opinion in 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
  • Acting as the expert witness in a cross-border tax case appointed by the Dutch court
  • Contributing to the expert witness report in 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 (Natland and others v. Czechia, PCA Case No. 2013-35, Final Award dated 15 December 2023)
  • Contributing the tax expert report in 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, the judgment of 19 October 2023)
  • Reviewer at “Journal of World Investment & Trade”,  “World Tax Journal”,  “Polish Yearbook of International Law,   “Intertax”,  “Accounting, Economics, and Law: A Convivium”, “Asia Pacific Law Review”, “Journal of Public Affairs”