PhD student of the month

March 2025: Johan Hagelin

Johan Hagelin has been a PhD student in fiscal law since 2022, writing his thesis on transfer pricing. He recently returned from a six-month research stay in Japan. His strong international interest has shaped both his doctoral research and his previous professional experiences. Although fiscal law—often referred to as tax law—wasn't initially the focus of Johan's career plans, it ultimately led him to exciting work and research opportunities.

- One thing led to another, and I ended up on a career path that I simply followed. I didn’t take any advanced courses in tax law during the LL.M. Program and my main interest was in public international law. Eventually, I decided to write my master's thesis on the interpretation of tax treaties under the guidance of Martin Berglund, a professor of fiscal law. We kept in touch in the years that followed and he is now my supervisor again.

After graduating from the LL.M. Program at Uppsala University, Johan worked at the Swedish Tax Agency before pursuing further studies in Japan. While there, he began an internship at the OECD (Organisation for Economic Co-operation and Development), focusing on international tax issues, and later worked with transfer pricing at the consulting firm Deloitte in Tokyo. It was also in Japan where Johan met his wife. After a few years in Tokyo, they moved to Amsterdam and then eventually returned to Sweden.

Johan Hagelin

Johan Hagelin Photo: Lasse Blom

- I wanted to gain a broader perspective on the work I was doing and was starting to feel a bit weary of consultancy, so I decided to apply for the doctoral program in Uppsala. You could say the research topic found me, rather than the other way around, through my experiences working in Tokyo and Amsterdam. Transfer pricing is an international, underexplored, and incredibly dynamic area of research.

We discuss transfer pricing as a research topic, which involves how the profits and losses of multinational corporations are treated for tax purposes. For instance, where should profits be taxed when a company operates in multiple countries? This ties into a larger question of how tax bases should be allocated across countries, raising concerns about tax fairness, double taxation, and tax avoidance.

International transfer pricing guidelines, which have been in place for many years and are applied globally, are of significant importance. In my thesis, I examine the historical evolution of the interpretation of the standard that forms the foundation of these guidelines, as well as its resilience in the face of changing economic and societal conditions. One notable change is digitalisation. Nowadays, companies can provide services and goods entirely through digital means to markets in other countries, without having a physical presence there. The effect of digitalisation on the interpretation of the standard is one of the key research questions in my study.

Johan is midway through his doctoral studies and feels that time is passing quickly, especially since the birth of his daughter two years ago. Despite the busyness of family life, he values the flexibility to occasionally slow his work pace to stay in sync with his family’s needs. He also enjoys the opportunity to engage in various other projects, particularly within international networks. One such network, MIRAI, connects researchers from universities in Sweden and Japan, fostering conferences and collaborations on interdisciplinary projects related to sustainability and innovation. Another network, SKERIC, enables similar partnerships with Korean researchers. Additionally, Johan serves as a doctoral student representative on the University Board at Uppsala University and works as an editor for Svensk Skattetidning, a Swedish tax journal.

Our conversation shifts back to Japan and his international interests. I ask how he managed to return there, now with his family, as part of his doctoral program.

- I reached out to tax law professors at a few different universities. Having lived in Japan before probably helped, as I could include some typical greetings, but mostly it was a matter of cold calling, which eventually paid off. A very welcoming professor at Kobe University invited me to attend his seminars.

I ask if his international interest will lead him to go abroad after completing his doctorate.

- I’m happy to be based in Uppsala and to continue a career with an international focus. There are many ways to go abroad—taking a sabbatical at a foreign university, traveling, or inviting researchers here. That’s the kind of life I want to create, one where I can combine work, travel, and family.

Thank you, Johan, for a nice coffee and for sharing your international research trip with me. I wish you good luck with the rest of your doctoral programme!

Rebecca Söderström

Fågelsången, 21 February 2025

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