The International Bureau of Fiscal Documentation (IBFD) has announced that Dr Qiang Cai has won the 12th IBFD Frans Vanistendael Award.
The International Bureau of Fiscal Documentation (IBFD) has announced that Dr Qiang Cai has won the 12th IBFD Frans Vanistendael Award.
The honour was received for his 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)).
This 10,000 Euro award ‘promotes and celebrates scientific research of the highest standards’. ‘An international jury judges the submitted publications and selects the work that makes the most outstanding contribution to the development of international tax law’ (IBFD).
Qiang’s work attempts to reconstruct the economic allegiance theory, which was endorsed and developed in the 1920s and has since been widely regarded as the bedrock of the modern international tax regime. He adopts an interdisciplinary approach by drawing on insights from transaction cost economics. The jury commented on his work as follows:
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. (IBFD)
Reflecting on the award, Qiang said: "The prize reinforces my belief that a law and economics approach may yield valuable insights for the theoretical construct of international taxation. I am also grateful for the generous support from the law school communities, where interdisciplinarity and multidisciplinarity have always been championed.”
Qiang’s theoretical work also feeds into his policy engagement. He has led the law school’s responses to multiple tax consultations launched by the OECD, the United Nations, and the UK Government. Since December 2024, he has been appointed a member of the International Tax Law Committee of the International Law Association (ILA).
The link to the IBFD’s press release on the award can be found here: Qiang Cai and Ricardo Andre Galendi Junior win the 12th IBFD Frans Vanistendael Award for International Tax Law | IBFD