Qiang Cai and Ricardo Andre Galendi Junior win the 12th IBFD Frans Vanistendael Award for International Tax Law
IBFD is proud to announce Qiang Cai and Ricardo Andre Galendi Junior as the winners of the 12th IBFD Frans Vanistendael Award for International Tax Law, a prestigious international prize recognizing outstanding scientific research in international taxation.
As of this year’s 12th edition, the award is conferred in two distinct categories as opposed to one, reflecting the breadth and diversity of academic contributions to the development of international tax law:
• IBFD Frans Vanistendael Award for Books
• IBFD Frans Vanistendael Award for Articles and Book Chapters
The winner of the IBFD Frans Vanistendael Award for Articles and Book Chapters is Qiang Cai for the publication ‘Reassessing the Economic Allegiance Theory from a Transaction Cost Perspective: What’s the Benefit Principle Got to Do with It?’ World Tax Journal 17, no. 4 (2025).
The winner of the IBFD Frans Vanistendael Award for Books is Ricardo Andre Galendi Junior for the publication The Justification and Structure of the GloBE Model Rules. IBFD Doctoral Series 78. IBFD, 2025.
About the winning publications
Qiang’s original approach to economic allegiance brings valid arguments to challenge the conventional view that the benefit principle underpins international taxation. The author’s conceptual framework makes economic allegiance suitable to operate without physical presence, thus in a way that might operate for both source and residence jurisdictions, stressing the value of human relations over things.
Galendi's book addresses issues of sovereignty and undertakes a comprehensive examination of the Pillar 2 GloBE rules, which should have been made before adopting them. Galendi addresses the reasons for the GloBE minimum tax, how the rules and taxing mechanism work, whose income is determined, what is burdened with the tax, where the burden is placed, and how the tax is imposed. Importantly, he critically evaluates the measures against their justifications.
About the winners
Dr Qiang Cai is a lecturer (associate professor) in Tax Law and Commercial Law at the School of Law, University of Aberdeen, where he also serves as Co-Director of the Aberdeen Centre for Commercial Law (ACCL). He has published extensively in international tax law, with a particular interest in the theoretical framework of international taxation.
Dr Ricardo André Galendi Júnior is a Partner at Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados, Professor in the Professional Master’s Program at the Brazilian Institute of Tax Law (Instituto Brasileiro de Direito Tributário – “IBDT”) and in the LLM in Tax Law at Insper. He holds a PhD in Tax Law (“summa cum laude”) from the University of Cologne, Germany, and a Master’s degree in Economic, Financial, and Tax Law from the University of São Paulo (USP).
IBFD warmly congratulates both winners on their exceptional achievements and valuable contributions to the advancement of international tax scholarship and research.
About the Frans Vanistendael Award for International Tax Law
The annual award promotes and celebrates scientific research of the highest standards. An independent international jury evaluates the submitted publications and selects the works that make the most outstanding contribution to the development of international tax law, including European Union tax law.
Applications and nominations for the 13th IBFD Frans Vanistendael Award for International Tax Law will open on 1 June 2026.
Further information, including the competition rules and eligibility requirements, is available on the award webpage: IBFD Frans Vanistendael Award for International Tax Law.