Edwin Vanderbruggen

Scholarly Articles

International

New developments in international climate change law

The landscape of international climate change law is in flux. In December 2024, the International Court of Justice held a hearing on the obligations of states under international law to fight climate change. As part of its deliberations, the court considered written statements from 91 states and organizations. Prof. Dr. Thomas Burri, Professor of Public […]

Aug 12, 2025

Cambodia

Questions about the Taxation of Cambodian Permanent Establishments in the Wake of the 2023 Amendment of the Law on Taxation

Cambodia’s Law on Taxation[1] featured a definition of “permanent establishment” (the Cambodian PE) from its first draft in 1997. The Cambodian PE functions much like in other countries as a source nexus for the Cambodian income taxation of business income derived from Cambodia by non-residents. Income from business activities by a non-resident taxpayer are only […]

Aug 04, 2024

Cambodia

What Are Digital Goods, Services and E-Commerce for Purposes of Cambodia's VAT Reverse Charge?

Since April 2022, born from the COVID boom of online business, a new and costly tax system was created in Cambodia to hit a very wide range of cross border transactions. Although taxpayers are supposed to implement this already for nearly 2 years, misunderstandings about the scope of the VAT Reverse Charge are widespread. In […]

Feb 26, 2024

Tax Treaty Renegotiations by Developing Countries: A Case Study Using Comparative Analysis to Assess the Feasibility of Achieving Policy Objectives

Tax treaties between industrialized countries and developing countries presently take up the majority of the world’s bilateral income tax treaties. Many of these tax treaties were concluded at a time when the developing country found itself in a less than desirable negotiating position. This article analyzes the considerations in determining the feasibility of a developing […]

Aug 01, 2022

Differences and Similarities between the OECD Transfer Pricing Guidelines and Vietnam Decree 132 (Conclusions)

This is the eight and last part in a series of contributions focused on analyzing Vietnam’s current key transfer pricing regulation Decree 132 from the perspective of the 2022 Transfer Pricing Guidelines (“TPG”) of the Organization for Economic Cooperation and Development (“OECD”).

Feb 06, 2020

Transfer Pricing for Costs, Services and Loans: The OECD Experienceand Comparisons with Vietnam

This is the seventh part in a series of contributions focused on analyzing Vietnam’s current key transfer pricing regulation Decree 132 from the perspective of the 2022 Transfer Pricing Guidelines (“TPG”) of the Organization for Economic Cooperation and Development (“OECD”).

Feb 06, 2020

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About

Edwin, a senior partner at VDB Loi, has over 30 years of experience in tax and legal matters. He advises international clients, consults for major organizations like the IFC and ADB, and has a strong academic background with awards for his publications. His expertise covers Southeast Asian legal reform and taxation.