Showing 1 - 12 of 72 publications
January 2022

The Politics of Taxing Multinational Firms in a Digital Age

by Martin Hearson & Margarita Gelepithis

Taxing multinationals is politically difficult because of the structural power of mobile firms within the global economy, and this structural power is expected to increase in the digital age. Recently however there has been a breakdown in the international corporate tax consensus that structured tax competition over the past century. A new norm of international…

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December 2021

Taxing Profits From International Transport In Africa: Past, Present and Future of Article 8 (Alternative B) of the UN Model

by Bob Michel & Tatiana Falcao

International maritime shipping is an essential part of global business. Since the establishment of the current international tax regime in the 1920s, there has been a consensus that profits generated by this business are taxable only in the residence state –the state where the shipowners are located. Source states – the port states where business…

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December 2021

Tax Treaties and Enterprise Outcomes: Evidence Across Developing African Countries

by Uchenna Efobi & Oluwabunmi O. Adejumo

Studies have noted the possibility of tax treaties constraining the tax policy autonomy of developing countries, while their impact on enterprise development within host economies remains an empirical issue. This study examines the effects and heterogeneous differences in estimated effects of tax treaties on small businesses in developing countries that agree to these agreements. The…

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November 2021

Taxing Profits from International Maritime Shipping in Africa: Past, Present and Future of UN Model Article 8 (Alternative B)

by Bob Michel & Tatiana Falcão

International maritime shipping is an essential part of global business. Since the establishment of the current international tax regime in the 1920s, there has been a consensus that profits generated by this business are taxable only in the residence state – the state where the shipowners are located. Source states – the port states where…

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November 2021

Tax Treaty Aggressiveness: Who is Undermining Taxing Rights in Africa?

by Lucas Millán-Narotzky, Javier García-Bernardo, Maïmouna Diakité & Markus Meinzer

Tax avoidance strategies by multinational companies rely heavily on tax treaties. Multinational companies can relocate financial activities across countries to ensure the applicability of the most beneficial tax treaties. This ‘treaty shopping’ can be particularly harmful to African countries, impairing their efforts for domestic resource mobilisation and achieving sustainable development goals. In this paper, we…

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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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July 2021

The Contested Shaping of International Tax Rules: The Growth of Services and the Revival of Fractional Apportionment

by Sol Picciotto

The digitalisation of the economy has spotlighted fundamental flaws in international tax rules, which have been exacerbated since the 1970s with the wider shift to the services economy and the growth of international services. These systemic flaws have been more evident from the perspective of countries that are mainly importers of services that have tried…

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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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March 2021

Profit Shifting of Multinational Corporations Worldwide

by Javier Garcia-Bernardo & Petr Janský

Multinational corporations (MNCs) avoid taxes by shifting their profits from countries where real activity takes place towards tax havens, depriving governments worldwide of billions of tax revenue. Earlier research investigating the scale and distribution of profit shifting has faced methodological and data challenges, both of which we address. First, we propose a logarithmic function to…

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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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