Raghav Aggarwal
Where treaties, tax systems, and legal designs meet.
I, Raghav Aggarwal, am an international tax lawyer and policy researcher working on cross-border legal frameworks, treaty interpretation, and global tax architecture.
Cross-border legal frameworks rarely operate in isolation. Tax treaties, trade agreements, domestic rules, and anti-avoidance standards intersect in ways that shape real outcomes for states and businesses.
My work examines these pressure points — across treaty interpretation, anti-avoidance, and the structural limits of cross-border tax systems — through writing, case commentary, and legal education.
About Me
My work examines where cross-border legal systems begin to strain in practice — where treaties, domestic tax rules, trade frameworks, and anti-avoidance standards intersect under commercial pressure.
I focus on how courts, administrators, and policymakers shape the boundaries of legitimate tax planning across jurisdictions, drawing on nearly two decades of cross-border legal work and graduate legal studies in Business & Tax laws at Boston University School of Law and Osgoode Hall Law School respectively.
Alongside research and writing, I develop legal education programs and contribute to academic and guest-lecture environments where law is examined as a system, not just a toolkit.
Research Focus
Treaties, Characterization & Cross-Border Architecture
How tax treaties, domestic law, and trade frameworks interact in practice — including beneficial ownership, characterization of income (business profits vs royalties/services), permanent establishment exposure, and treaty access under real commercial structures.
Anti-Avoidance, System Integrity & Anti-Deferral
GAAR, treaty abuse, Principal Purpose Test logic, conduit structures, commercial substance, and the coherence of anti-deferral regimes such as CFC/FAPI frameworks. Focus on how anti-avoidance rules operate across jurisdictions rather than in isolation.
System Design, Tax Policy & Institutional Constraints
How tax systems are structured, interpreted, and implemented in practice — and how policy choices, administrative design, and institutional limits shape the real-world functioning of cross-border tax frameworks.
Latest Writing
Recent case commentary, policy analysis, and research notes.
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How Much Substance is Adequate? Legal Certainty and the Adequacy Threshold in the UAE Free Zone Corporate Tax Regime
How much substance is adequate under the UAE Free Zone Corporate Tax regime? This article examines the legal uncertainty around adequate substance, Core Income-Generating Activities, and the 0% Free Zone tax rate, and proposes a proportionality-based approach to improve certainty for taxpayers and the Federal Tax Authority.
Professional Inquiries
For academic collaboration, policy consultation, guest lectures, or research dialogue