Dr Amir Pichhadze





Faculty of Business and Law


BL Law


Melbourne Burwood Campus


Dr. Amir Pichhadze teaches business tax law. He obtained a Doctor of the Science of Law (S.J.D.) as well as an LL.M. in International Tax, both at the University of Michigan Law School. His doctoral research, which was carried out under the supervision of Professor Reuven S. Avi-Yonah, exposed, explained and alerted about the necessary role of contractual interpretation in the law of transfer pricing. This research can be found in the Canadian Tax Journal, the World Tax Journal, and the International Transfer Pricing Journal. A summary of Pichhadze’s thesis can be found in this news article: “Insights into Transfer Pricing Guidelines (Post-BEPS)”.

Prior to his studies at Michigan, he completed a Judicial Clerkship at the Tax Court of Canada, and obtained an LL.M. (Taxation) and LL.B.; both from the London School of Economics and Political Science.

Amir’s legal research has been published in peer-reviewed and peer-edited journals and magazines around the world. Part of his research, which was published in the Bulletin for International Taxation (Vol. 69(9)), was awarded second place in the 2013 Annual Law Student Essay Competition of the American Judges Association (AJA).

Amir presented his legal research in numerous academic and professional conferences around the world. Most recently, he presented articles at the:
5th Annual Tax Administration Research Center (TARC) Workshop;
• the 8th Queensland Tax Researcher’s Symposium (QTRS); and
• the 2017 Australasian Law Teachers Association Annual Conference;

In the coming future, his research will also be presented at:
• The Australasian Tax Teachers Association (ATTA) 2018 Conference;
• The Spiegel Sohmer Tax Policy Colloquium at McGill University’s Faculty of Law;
• the Graduate Tax Program Lecture Series at the Boston University School of Law;
• the Institute for Austrian and International Tax Law at WU, where he will be a Senior Visiting Research Fellow (Full Professor)
• the IBFD’s 16th edition of the Postdoctoral International Tax Forum (PITF), and
• the Max Planck Institute for Tax Law and Public Finance, where he will be a Visiting Scholar;

He will also be a Guest Teacher at the London School of Economics and at Osgoode Hall Law School.

Amir is also a Referee for the journal ‘Accounting, Economics, and Law: A Convivium’.

Read more on Amir's profile

Research interests

  • Taxation
  • Law of Contracts
  • Judicial contractual and statutory interpretation


  • Lifetime Member, Honor Society of Phi Kappa Phi, USA
  • Australasian Law Teachers Association (ALTA)
  • Australasian Tax Teachers’ Association (ATTA)
  • International Fiscal Association (IFA) – Australian Branch

Teaching interests

  • Business tax law
  • International taxation
  • Consumption taxes
  • Contract law
  • Judicial contractual and statutory interpretation

Knowledge areas

  • Tax Law
  • Law of Contracts
  • Judicial contractual and statutory interpretation


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GAARs and the Nexus between statutory interpretation and legislative drafting: lessons for the U.S. from Canada

R Avi-Yonah, A Pichhadze

(2017), Vol. 7, pp. 1-7, Accounting, Economics, and Law: A Convivium, Berlin, Germany, C1-1


Delineating the terms of a single composite transaction in transfer pricing: the role of step-transaction analysis in the aggregation of interrelated (linked) contracts

A Pichhadze

(2016), Vol. 23, pp. 179-199, International transfer pricing journal, Amsterdam, The Netherlands, C1-1


Contractual interpretation in tax disputes: insights from Canada

A Pichhadze

(2015), Vol. 79, pp. 685-695, Tax Notes International, United States, C1-1


The arm's length comparable in transfer pricing: a search for an "actual" or a "hypothetical" transaction?

A Pichhadze

(2015), Vol. 7, World Tax Journal, Netherlands, C1-1


Exposing unaddressed issues in the OECD's BEPS project: what about the roles and implications of contract interpretation law and private international law in the transfer pricing arm's length comparability analysis?

A Pichhadze

(2015), pp. 99-167, World Tax Journal, Netherlands, C1-1


Allocation of Income and Deductions Among Taxpayers Under Section 482 of the United States Internal Revenue Code: Alerting the Courts to the Role of Contractual Interpretation Law in the Transfer Pricing Arm's Length Comparability Analysis

A Pichhadze

(2015), Vol. 22, pp. 156-166, International Transfer Pricing Journal, C1-1


Calling on U.S. Courts to Adopt Canada's Unified Approach to Statutory Interpretation

A Pichhadze

(2014), Vol. 15, The Journal of Appellate Practice and Process, C1-1


Can, and Should, the Parol Evidence Rule be Invoked By or Against Tax Authorities in Tax Litigation? Distilling lessons from U.S. jurisprudence

A Pichhadze

(2013), Vol. 67, pp. 474-490, Bulletin for International Tax, C1-1


Canada's Transfer Pricing Test in the Aftermath of GlaxoSmithKline Inc. v. R.: A Critique of the "Reasonable Business Person Test

A Pichhadze

(2013), Vol. 20, pp. 144-162, International Transfer Pricing Journal, C1-1


Input tax credits: what Canada's federal court of appeal could have learned from the U.K. VAT

A Pichhadze

(2013), Vol. 70, pp. 267-282, Tax Notes International, United States, C1-1


Making the case for increased "judicial globalization" in consumption tax law

A Pichhadze

(2008), Vol. 56, pp. 367-388, Canadian Tax Journal, Canada, C1-1


Proposals for reforming the law of self-defence

A Pichhadze

(2008), Vol. 72, pp. 409-440, The Journal of Criminal Law, United Kingdom, C1-1



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