International Tax

Low-income countries are more dependent on corporate income tax revenue than richer countries, and at the same time, disproportionately affected by multinational tax avoidance. Our research on this theme investigates ways in which developing countries can protect their tax bases, including through simplified transfer pricing methods and improved tax treaty policies. Our work on this theme also includes examination of the OECD’s Base Erosion and Profit Shifting (BEPS) process from the perspective of developing countries, as well as exploring alternative methods of taxing multinational companies, namely unitary taxation.

Publications:

March 2018
Chapter 1: Taxing Multinational Business in Low-Income Countries
by Michael C. Durst

The book explores a topic that has been highly controversial in recent years: the use by multinational companies of “base erosion and profit shifting” tax planning structures to reduce their tax liabilities in countries where they conduct business, including the world’s lower-income developing countries. In this instalment, which is Chapter 1, the author provides an…

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November 2017
Assisting Developing Countries in Taxation after the OECD’s BEPS Reports: A Suggested Approach for the Donor Community
by Michael C. Durst

This paper explores how the international donor community might most productively offer technical assistance to developing countries in the area of taxation, in light of the OECD’s recently completed study of ‘base erosion and profit shifting’ (BEPS). The paper addresses both the political and the technical constraints facing developing country tax administrations. It recommends that…

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November 2017
How Can Governments of Low-Income Countries Collect More Tax Revenue?
by Mick Moore & Wilson Prichard

It is widely believed that the governments of many low-income countries, and especially the relatively poor performers, should be aiming to increase the proportion of GDP they raise in tax revenue. There are risks in emphasising increasing revenue at the expense of other objectives. Governments also need to be concerned with questions of equity, efficiency,…

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October 2017
How Kenya has Implemented and Adjusted to the Changes in International Transfer Pricing Regulations: 1920-2016
by Attiya Waris

A large proportion of international trade in goods and services is conducted between what are known technically as related parties. In practice, most of this trade is between different companies forming part of the same transnational corporate grouping. This is typically highly integrated in economic and financial terms, while legally appearing as a set of…

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CMI Publication: Lifting the Veil of Secrecy – Perspectives on International Taxation and Capital Flight from Africa
by Odd-Helge Fjeldstad, Sigrid Klæboe Jacobsen, Peter Henriksen Ringstad & Honest Prosper Ngowi

This book is produced as a part of the research project Taxation, Institutions and Participation (TIP). TIP investigates the effects of tax havens on domestic revenue systems, institutions and on citizen participation in African countries. The project aims to generate new, contextualised evidence on the political economy of domestic revenue mobilisation, institutional development and state…

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June 2017
What Have We Learned About International Taxation and Economic Substance?
by Sol Picciotto

The landscape of international corporate taxation will change significantly as a result of the G20/OECD project on base erosion and profit shifting (BEPS). The contours of this new terrain have become apparent since the publication of the main outputs of the project in October 2015.The BEPS outputs aim to strengthen the system and give better…

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Global distribution of revenue loss from tax avoidance – Re-estimation and country results
by Alex Cobham & Petr Janský

International corporate tax is an important source of government revenue, especially in lower-income countries. An important recent study of the scale of this problem was carried out by International Monetary Fund researchers Ernesto Crivelli, Ruud De Mooij, and Michael Keen. We first re-estimate their innovative model, and then explore the effects of introducing higher-quality revenue…

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February 2017
Taxing Multinational Enterprises as Unitary Firms
by Sol Picciotto ed.Sol Picciotto

The international tax system needs a paradigm shift. The rules devised over 80 years ago treat the different parts of a multinational enterprise as if they were independent entities, although they also give national tax authorities powers to adjust the accounts of these entities. This creates a perverse incentive for multinationals to create ever more…

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February 2017
Tax Base Erosion and Profit Shifting in Africa – Part 2: A Critique of Some Priority OECD Actions from an African Perspective
by Annet Wanyana Oguttu

In Part 2 of this article, the author continues her examination of the implications of the OECD’s Action Plan on Tax Base Erosion and Profit Shifting from an African perspective. Although the OECD Project covers 15 Actions to address BEPS, the low economic development of many African countries, their limited administrative capacity and general lack…

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January 2017
Transfer Pricing in Argentina 1932-2015
by Veronica Grondona & Andres Knobel

This document provides a review of the Argentine tax authority’s structure for dealing with transfer pricing in Argentina; a chronological review of the legislative transfer pricing framework; and a very extensive listing of the transfer pricing cases that have reached different court levels. The document also summarises some of the difficulties encountered in relation to…

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Blogs:

March 2018
by Alexandra Readhead & David Mihalyi

This piece is available in Mongolian here. Governments of mining countries are vulnerable to investors using double tax agreements (DTAs) as a means of avoiding paying taxes. DTAs are bilateral, or multilateral agreements between countries that set out which country has the right to collect tax on different types of income. Interest expense on foreign…

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January 2018
by Mick Moore

In the past two decades, the debate on international taxation has changed considerably. While the system is still biased against the governments of developing countries, the politics have moved in their favour. If they are able to organise and work collectively, they have scope to make the international tax system less unfair. The system for…

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December 2017
by Obafemi Awolowo University Tax Club

Nigeria is one of the fastest-growing online nations on earth, with 91.6 million Nigerians online as of mid-2017, according to the country’s Communications Commission. But taxing this digital domain is still very much in the analogue era. Akintunde Agunbiade, Tolu Dada, Emmanuel Faith, Oreniyi Adesewa, Solomon Nzere, Ikusika Bamidele, Omotoso Feranmi, Anifowose Jadesola, Adelabu Adepeju,…

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