Biography

Dr Anzhela Cédelle (née Yevgenyeva) is Senior Research Fellow at the Oxford University Centre for Business Taxation, Saïd Business School, and Associate Member of the Oxford Law Faculty. Her areas of expertise include tax and EU laws, and she has a strong interest in the intersection of domestic, EU and international tax regulation. Anzhela teaches EU tax law to postgraduate students at Oxford (MSc in Taxation, BCL, MLF and MJur). She is Managing Editor of the encyclopedia  D. Vaughan and A. Robertson (eds.), The Law of the EU (Oxford University Press), and a convenor of the Tax Section of the Society of Legal Scholars and the Oxford EU Law Discussion Group

Anzhela was awarded a doctoral degree in law by the University of Oxford, where she had previously completed her master’s in law (distinction). She obtained a GDL (distinction) from the University of Law in London and holds a BA and MA in law (honours) from the Law School of Kyiv-Mohyla Academy in Ukraine. Anzhela has won a number of prestigious scholarships and prizes, which include those awarded by the UK Government, the University of Oxford and the Honourable Society of the Inner Temple. Her doctoral thesis on direct taxation and the Internal Market won the 2014 ELFA First Award for the best thesis on European Law from the European Law Faculties Association, and it was also granted an Honourable Mention in the competition for the 2013 Mitchell B. Carroll Prize for the best thesis on fiscal matters by the International Fiscal Association. 

Her professional experience has been gained in common law and civil law jurisdictions. It includes advisory work for state authorities and international organisations, oriented towards the improvement of legal regulation. Her expert opinion was recently cited by HM Treasury in a report that considers what EU membership means for the UK and taxation, which was published as a part of the UK Government’s Balance of Competences Review.

Publications

Displaying 1 - 10 of 10. Sorted by year, then title.
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  • (Yevgenyeva) Cédelle, 'The EU Anti-Tax Avoidance Directive: A UK Perspective' [2016] British Tax Review 490
    The EU Directive laying down rules against tax avoidance practices that directly affect the functioning of the Internal Market—the so-called Anti-Tax Avoidance Directive (ATAD)—was adopted on 12 July 2016. It has become one of the core vehicles for implementing the output of the Base Erosion and Profit Shifting (BEPS) initiative, a process led by the G20 and the Organisation for Economic Cooperation and Development (OECD), at the EU level. The ATAD has imposed a legally binding obligation upon EU Member States to incorporate the conclusions of Action 2 (hybrid mismatch arrangements), Action 3 (controlled foreign company (CFC) rules) and Action 4 (interest deductions) of the BEPS in their domestic laws and regulations, and it has secured a certain uniformity of national implementing measures across the EU by imposing a common minimum level of protection. In addition, the ATAD has also set out a general anti-abuse rule (GAAR) and exit tax provisions, which further strengthen the EU’s baseline protection of tax revenues. The potential impact of this milestone Directive on the Internal Market and the tax systems of Member States in a short-to long-term period is still to be evaluated. This article offers preliminary thoughts, focusing primarily on the UK’s perspective. The author first briefly addresses possible consequences for the EU as a whole, and then analyses the ATAD from the UK’s point of view, showing how the adoption of this Directive fits into a broader UK tax policy and law both prior to and following the Brexit vote.
  • (Yevgenyeva) Cédelle and Vella, 'Differentiated Integration in the EU: Lessons from the Financial Transaction Tax' in Koutrakos and Snell (eds), Research Handbook on the Law of the EU’s Internal Market (Edward Elgar 2016) (forthcoming)
  • (Yevgenyeva) Cédelle, 'Enhanced Cooperation: A Way Forward for Tax Harmonization in the EU?' in J Englisch (ed), International Tax Law: New Challenges to and from Constitutional and Legal Pluralism (IBFD 2016)
    ISBN: 978-90-8722-374-8
  • (Yevgenyeva) Cédelle, Revising CFC Rules in the BEPS Context (Action 3), paper presented at The 2016 Winter Course on International Tax Law, organised by the University of Amsterdam (15 January 2016, Amsterdam, the Netherlands)
  • (Yevgenyeva) Cédelle, Vella and Devereux, EU Law and the OECD/G20 BEPS Deliverables: Potential Conflicts, paper presented at The 2015 European Tax Policy Forum 'Britain, Europe and Tax Competition' (1 June 2015, London)
  • (Yevgenyeva) Cédelle, The Balance of Competences between the United Kingdom and the European Union: Taxation (written evidence submitted to HM Treasury for the UK government’s Balance of Competences Review 2013)
  • Englisch, Vella and (Yevgenyeva) Cédelle, 'The Financial Transaction Tax Proposal under the Enhanced Cooperation Procedure: Legal and Practical Considerations' [2013] British Tax Review 223
    This article examines the European Commission’s Proposal for a Council Directive implementing a financial transaction tax through the enhanced cooperation procedure published on February 14, 2013. It starts by providing a brief description and analysis of the Proposal and the accompanying Impact Assessment, focusing on the newly added features of the proposed tax and its potential impact on both participating and non-participating Member States. Next, the article examines the Proposal from the perspective of public international law, discussing the controversial extraterritorial reach of the proposed tax. It is argued that doubts exist with respect to the compatibility of the “contagion effect” and the issuance principle with internationally recognised legal principles. The article then turns to EU law and considers the legal requirements imposed by the EU Treaties on the use of enhanced cooperation. Whilst raising some concerns in relation to the Proposal’s compliance with these requirements, the article concludes that the political and judicial controlling mechanisms in place appear weak and therefore the outcome of any potential political or judicial challenge remains uncertain. The importance of this debate is not limited to the financial transaction tax, but also extends to the use of enhanced cooperation in other areas of taxation and beyond.
    ISBN: 0007-1870
  • Englisch and (Yevgenyeva) Cédelle, 'The Upgraded Strategy against Harmful Tax Practices under the BEPS Action Plan' [2013] British Tax Review 620
    The Action Plan on Base Erosion and Profit Shifting (Action Plan) intends to "revamp" the work on harmful tax practices that has been undertaken by the Organisation for Economic Co-operation and Development (OECD) since the late 1990s. Further enhancement of the OECD’s transparency standards, the reinforcement of the requirement of a "substantial activity" for any "acceptable" preferential tax regime and an ambition to ensure a closer engagement of non-OECD economies re-open the debate on "harmful tax competition" that sparked in the academic literature and political arenas following the first attempt of international co-ordination. This article discusses the priority measures that are envisaged by Action 5 of the Action Plan and their foreseeable prospects. It demonstrates that the OECD is merely seeking to upgrade its existing mandate and exploit the political momentum that has been created by the BEPS campaign. The proposed strategy aims to adjust the current methods and structures rather than offer a conceptual rethinking.
    ISBN: 0007-1870
  • (Yevgenyeva) Cédelle, 'EU Legislative Process and the National Parliaments: Symbolic Importance and Practical Implications of the Treaty of Lisbon' in Huber and Ziegler (eds), The EU and National Constitutional Law (Richard Boorberg Verlag 2012)

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EU Law, Taxation

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European Union Law, Taxation Law

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