Showing 1 - 12 of 12 publications

Using New Data to Support Tax Treaty Negotiation

by Martin Hearson, Marco Carreras & Anna Custers

This paper introduces the new Tax Treaties Explorer dataset, developed with support from the World Bank and the G-24, and illustrates its use for research by tax treaty negotiators, policy makers, and researchers. The new dataset provides a rich source of data to reexamine existing tax treaty policy, inform negotiation positions, and assess treaty networks….

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Tax Treaties of G-24 Countries: Analysis Using a New Dataset

by Martin Hearson

Between them, the G-24 countries have over 800 bilateral tax treaties in force. Each treaty limits states’ ability to tax income earned within their borders by investors and service providers from the treaty partner. As well as constraining states’ ‘taxing rights’, they are also vulnerable to abuse through ‘treaty shopping’. A new dataset of developing…

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“An Unacceptable Surrender of Fiscal Sovereignty:” The Neoliberal Turn to International Tax Arbitration

by Martin Hearson & Todd Tucker

This article examines the growth of inequality over the past half century, which is closely connected to the rise of neoliberal policies and institutions and the latter of which shield capital from state actions that might limit wealth accumulation. Economic nationalism since the global financial crisis has slowed or even reversed this, yet this same…

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May 2021

Imposing Standards: The North-South Dimension to Global Tax Politics

by Martin Hearson

In Imposing Standards: The North-South Dimension to Global Tax Politics, ICTD Research Fellow Martin Hearson shifts the focus of political rhetoric regarding international tax rules from tax havens and the Global North to the damaging impact of this regime on the Global South. Even when not exploited by tax dodgers, international tax standards place severe limits…

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December 2020

At the Table, Off the Menu? Assessing the Participation of Lower-Income Countries in Global Tax Negotiations

by Rasmus Corlin Christensen, Martin Hearson & Tovony Randriamanalina

For half a century, the most influential international rules and standards for taxing multinational corporations have been formulated by a select group of developed countries, the OECD, with lower-income countries on the outside. Since 2013, this has changed: decision making at the OECD has moved to the ‘Inclusive Framework’ (IF), which today encompasses 137 jurisdictions….

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December 2020

At the Table, Off the Menu? Assessing the Participation of Lower-Income Countries in Global Tax Negotiations

by Rasmus Corlin Christensen, Martin Hearson & Tovony Randriamanalina

Since 2013, the formal structure of global corporate tax policymaking at the OECD has changed. Decisions are no longer made by 37 OECD members, but by 137 countries from all regions and levels of development through the ‘Inclusive Framework’ (IF). Official documentation emphasises that all countries participate on an ‘equal footing’, but some participants and…

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The Appropriateness of International Tax Norms to Developing Country Contexts

by Martin Hearson, Joy W. Ndubai & Tovony Randriamanalina

This FACTI Background Paper considers six sets of international tax norms: tax treaties (often known as double taxation agreements), transfer pricing rules, mutual assistance agreements between states, state-state and investor-state tax dispute resolution mechanisms, coercive mechanisms that oblige states to adopt international tax norms or face sanctions from powerful states, and finally the embryonic framework…

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January 2020

Corporate Tax Negotiations at the OECD: What’s at Stake for Developing Countries in 2020?

by Martin Hearson

We could be in the midst of the biggest change to the way multinational companies are taxed in decades. In January 2019, over 130 developed and developing countries committed to ‘go beyond’ some of the fundamental principles that have underpinned cooperation on corporate taxation for a century (OECD 2019a). They opened negotiations to redistribute ‘taxing…

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The New Politics of Global Tax Governance: Taking Stock a Decade After the Financial Crisis

by Rasmus Corlin Christensen & Martin Hearson

The financial crisis of 2007–2009 is now broadly recognised as a once-in-a-generation inflection point in the history of global economic governance. It has also prompted a reconsideration of established paradigms in international political economy (IPE) scholarship. Developments in global tax governance open a window onto these ongoing changes, and in this essay we discuss four…

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November 2018

China’s Challenge to International Tax Rules and the Implications for Global Economic Governance

by Martin Hearson & Wilson Prichard

Twentieth century institutions of global economic governance face a profound challenge adapting to the rise of emerging markets and, especially, China’s rise. This is especially the case for the international tax regime, whose institutional home is the OECD and which is based on norms that favour capital exporting states. To understand the nature of the…

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March 2016

A Review of Uganda’s Tax Treaties and Recommendations for Action

by Martin Hearson & Jalia Kangave

In June 2014, Uganda announced the temporary cessation of bilateral tax treaty negotiations, and a review of its policy towards such treaties. The main effect of tax treaties is to divide up the ‘rights’ to tax cross-border investment between the state parties, which reduces the possibility that businesses will incur double taxation; in doing so,…

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