Many lower-income countries have spent years incorporating international tax rules into their legal frameworks. But how these rules actually function once embedded in domestic systems is a different question – and one that has received far less attention.
New research from the International Centre for Tax and Development (ICTD) puts that question at the centre. The ‘Comparative Perspectives on International Tax from the Global South’ project, started in 2024, examines how governments in seven countries – Ghana, Kenya, Nigeria, Pakistan, Peru, Uganda, and Zambia – engage with international tax standards in practice, focusing on exchange of information, bilateral tax treaties, transfer pricing rules, and digital services taxation.
At the heart of this project is a synthesis paper, ‘Global Rules, Local Realities: Lessons from the Global South on International Tax Standards’, which draws together findings across all seven country case studies, identifying shared patterns while also accounting for the ways country experiences diverge.
Uneven implementation of international tax standards
One of the project’s central findings is that adopting international tax standards does not produce uniform outcomes. Countries may incorporate rules into legislation or formal policy frameworks, but how they function day-to-day depends on how tax administrations interpret them, the resources available, and how they fit within broader reform agendas. As a result, implementation tends to be uneven; some elements of a standard may be prioritised while others are introduced more gradually or applied less consistently.
Research Director Martin Hearson, who leads ICTD’s international tax work, said: “International standards can deliver benefits where domestic conditions allow, but, where they do not, there is a risk that substantial investment will deliver only limited returns.”
The research also finds that most governments have stuck closely to the standard international model, even where simpler approaches might have suited them better. However, governments differ when it comes to sequencing reforms over time or narrowing the scope of implementation.
These adaptations are often shaped by resource and capacity constraints, but they also reflect deliberate strategic choices about where to direct limited administrative effort.
Researcher Frederik Heitmüller said: “When implementing international tax standards, countries should think creatively about sequencing, prioritisation, and alternatives.”
Cross-country comparison allows analysis of unique interaction between domestic insitutions and global standards
Examining seven countries together allows the project to surface patterns that single-country studies can miss. Certain challenges recur across contexts, particularly the demands complex standards place on tax administrations, and the sustained investment in specialised skills and systems that effective implementation requires.
At the same time, each country experience also differs in meaningful ways. Differences in legal frameworks, institutional arrangements, and policy priorities all shape how standards are interpreted and applied in practice. For instance, the presence or absence of a strong court system influences how much leeway tax administrations have when applying transfer pricing rules.
Taken together, the findings suggest that international tax standards do not function as a single, uniform system. Instead, they take shape through their interaction with domestic institutions. This has implications for how standards are designed and how implementation support is structured, particularly as international tax discussions continue to evolve. (See our work around the UN Framework Convention on International Tax)
Meet the researchers
ICTD presented the findings of the project in a public webinar on 7 July:
Country Case studies and further resources
To access all case studies and read more about the project, visit this webpage. For each of the country case studies, check out:
- Ghana and International Tax Standards: A Cautionary Tale?
- Evaluating Kenya’s Experience with International Tax Standards: Adoption, Suitability, and Effectiveness
- Taxing Choices: Reconciling Global International Tax Standards with Pakistan’s Domestic Tax Realities
- Global Rules, Local Challenges: Peru’s Adoption of International Tax Standards
- Implementation of International Tax Standards in Lower- and Middle-Income Countries: The Experience of Uganda
- Implementation of International Tax Standards in Zambia
