# RA

> International Tax | Policy | Teaching


## Posts

- [Chapter 1: 
Information Is Not Proof - When Exchanged Tax Data Becomes a Domestic Assessment](https://raghav-aggarwal.com/information-is-not-proof-chapter-1/): Tax authorities now receive unprecedented volumes of cross-border financial information. But an official exchange does not turn a reported account, balance or payment into proof of undeclared income. This pilot chapter argues that exchanged information should identify what must be examined, not predetermine the outcome of that examination.
- [How Much Substance is Adequate? 
Legal Certainty and the Adequacy Threshold in the UAE Free Zone Corporate Tax Regime](https://raghav-aggarwal.com/uae-free-zone-corporate-tax-adequate-substance/): 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.
- [When War Relocates Corporate Management: Tax Residence, Treaty Relief, and PE Risk](https://raghav-aggarwal.com/corporate-residence-relocation/): War-driven relocation of management can unexpectedly trigger corporate residence, treaty, and permanent establishment risks across borders.
- [Permanent Establishment Certainty under the UAE-Canada CEPA](https://raghav-aggarwal.com/uae-canada-cepa-permanent-establishment/): Part II turns to permanent establishment risk, analysing how treaty language and Canadian domestic law interact in determining tax nexus for UAE-based enterprises. It considers whether interpretational certainty keeps pace with the realities of remote service provision and mobile commercial presence.
- [UAE - Canada CEPA & Practical Access to Treaty Benefits.](https://raghav-aggarwal.com/uae-canada_cepa/): Part I examines the practical barriers to treaty access in cross-border service arrangements, with particular focus on Regulation 105 withholding and administrative pathways to DTAA relief. It evaluates whether expanded trade commitments under CEPA are matched by procedural tax clarity in implementation.

## Pages

- [About](https://raghav-aggarwal.com/about/): About Raghav Aggarwal Professional Journey My professional journey spans nearly two decades at the intersection of business law, taxation, and cross-border legal design. I began my career in a multi-generational legal practice where tax and business questions were inseparable from commercial reality. From the outset, I learned to approach law not as isolated doctrine, but as a system of interacting choices that shape economic outcomes. Early exposure to tax disputes, structuring issues, and client decision-making formed the practical foundation of my work. Seeking to deepen the business-law dimension of that foundation, I pursued my first LL.M. in American and International Business […]
- [Research & writings](https://raghav-aggarwal.com/research-writings/): Research & Writings
- [Home](https://raghav-aggarwal.com/): About Me I work at the intersection of law, taxation, and policy design, where cross-border systems meet real economic activity. My professional life has been shaped by one central idea: legal rules matter most not in theory, but in how they operate in practice, under pressure, and across jurisdictions. My path into this space was not linear, but cumulative. Training in business law, securities, arbitration, and regulatory systems gave me an early understanding of how commercial structures are built. Years in cross-border practice then showed me how those structures are tested by tax treaties, withholding rules, permanent establishment thresholds, anti-avoidance standards, […]

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