Raghav Aggarwal
Where treaties, tax systems, and legal designs meet.
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.
Explore →
Latest Writing
Recent case commentary, policy analysis, and research notes.
-
When Trade Meets Tax: CEPA and Practical Access to Treaty Benefits.
How trade agreements, tax treaties, and domestic withholding systems interact in practice. A systems-level analysis of UAE–Canada CEPA, Regulation 105, and real-world treaty access.
Professional Inquiries
For academic collaboration, policy consultation, guest lectures, or research dialogue