Erika Isabella Scuderi

Biography

Professor Scuderi’s research focuses on tax law and public international law, with particular attention to the normative foundations of income taxation and the exercise of tax jurisdiction over areas beyond national sovereignty. Her recent article, On Sovereignty, Outer Space, and Taxation, published in 104 Neb. L. Rev. 421 (2026), proposes a Tax Jurisdiction by Registration Principle, arguing that the registration of a space object under Article VIII of the Outer Space Treaty supplies a legal basis for taxing income derived from its use. The article has been featured on Forbes and The Economist and was discussed during an episode of the Tax Notes Podcast. Her works-in-progress cover a range of topics, including the role of the concept of “deservingness” in the architecture of the U.S. federal income tax, the geographical scope of bilateral tax treaties, and the scope of income sourcing rules in the Internal Revenue Code.

Before coming to Suffolk, Professor Scuderi was a Visiting Assistant Professor in Tax Law at the University of Florida Levin College of Law. In 2024, she served as a Postdoctoral Associate at the Space Policy Institute of The George Washington University and, in 2023, she was a visiting researcher at Harvard Law School. From 2020 to 2024 she was a Teaching and Research Associate at the Institute for Austrian and International Tax Law at the Vienna University of Economics and Business (WU), where she taught European and international taxation and received her Doctoral degree in July 2024. Her Doctoral dissertation on the taxation of space commerce was awarded several prizes, including the 2025 Tax Thesis Award by the European Commission and the European Association of Tax Law Professors, and an Honorable Mention for the Mitchell B. Carroll Prize. Before entering academia, Professor Scuderi practiced as a tax consultant at PwC Tax and Legal Services and at Chiomenti in Milan.

Selected Publications

Articles

• Taxation and Continental Shelf: A comment on the decision of the Italian Corte di Cassazione, Sez. V, no. 14549/2025, 2 Revue européenne et internationale de droit fiscal 205 (2026)
• On Sovereignty, Outer Space, and Taxation, 104 NEB. L. REV. 421 (2026)
• Tax Incentives for the Space Economy and the Potential Impact of Pillar II, 49 AIR AND SPACE LAW, 69 (2024),/li>
• “Provisions Primarily of a Fiscal Nature”: Time to Dispel Doubts, 31 EC TAX REVIEW (2022)

Books

• TAXATION OF OUTER SPACE INCOME IN DOMESTIC AND INTERNATIONAL TAX LAW: A PRINCIPLED AND NORMATIVE TAX POLICY EVALUATION (BOOK PROJECT)

Book Chapters

• Introduction to Space Taxation, in REGULATING SPACE-BASED COMMERCE: INSIGHTS FROM ECONOMICS AND INTERNATIONAL ECONOMIC LAW (Rodrigo Polanco et al. eds., forthcoming)
• Use of Fiscal Measures for Addressing Space Debris, in THE ECONOMICS OF SPACE SUSTAINABILITY: DELIVERING ECONOMIC EVIDENCE TO GUIDE GOVERNMENT ACTION, 108 (Claire Jolly & Marit Undseth eds., 2024)
• The Relevance of Article 21(2) of the OECD and UN Models, in PRIORITY RULES IN TAX TREATIES – THE RELATION BETWEEN THE DIFFERENT DISTRIBUTIVE RULES IN THE OECD AND THE UN MODEL CONVENTION, 53 (Georg Kofler et al. eds., 2023) (with Georg Kofler) (2023)
• A Case for Environmental Taxation as a Response to the Covid-19 Economic Crisis, in TAX LAW IN TIMES OF CRISIS AND RECOVERY, 223 (Peter Harris et al. eds., 2023) (with Amedeo Rizzo & Artemis Loucaidou)

Media

• Tax Notes Podcast: Taxation in Outer Space: How Countries Could Vie for Star Power
• Forbes: Taxation In Outer Space: How Countries Could Vie For Star Power
• The Economist: How to tax businesses in orbit and beyond, May 28, 2026

SSRN

Education

• Doctoral Degree, Vienna University of Economics and Business
• LL.M. (Equivalent) in Taxation, Bocconi University
• J.D. (Equivalent), Università degli Studi di Milano-Bicocca

Awards & Honors

• Doctoral Degree awarded with Honors, WU Wien (2024)
• 2025 European Commission & European Association of Tax Law Professors (EATLP) European Doctoral Tax Thesis Award (for Ph.D. Thesis)
• 2025 Honorable Mention for the International Fiscal Association (IFA) Mitchell B. Carroll Prize (for Ph.D. Thesis)
• 2025 Stephan Koren Preis (Vienna University of Economics and Business)
• 2022 & 2023 Vienna University of Economics and Business Research Award for Outstanding Research Achievements
• 2023 European Space Agency/ECSECO Paper Competition Award