Showing 1 - 12 of 67 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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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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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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Tax Amnesties in Africa: An Analysis of the Voluntary Disclosure Programme in Uganda

by Solomon Rukundo

Tax amnesties have taken centre stage as a compliance tool in recent years. The OECD estimates that since 2009 tax amnesties in 40 jurisdictions have resulted in the collection of an additional €102 billion in tax revenue. A number of African countries have introduced tax amnesties in the last decade, including Nigeria, Namibia, South Africa…

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December 2020

A Simplified Method for Taxing Multinationals for Developing Countries: Building on the ‘Amount B’ Proposal to Repair the Transactional Net Margin Method

by Michael C. Durst

The OECD’s Inclusive Framework is currently considering two substantial tax reform plans, Pillar One and Pillar Two. These are intended to develop a global consensus on methods for taxing the digitalised economy, but in their current form would have broad implications for international tax architecture in general, and particularly for the control of base erosion…

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December 2020

The Taxation of the Digitalised Economy: An African Study

by Mustapha Ndajiwo

African economies need adequate revenues for development, but weak tax laws, illicit financial flows and aggressive tax planning have made it difficult for them to attain their full potential in raising revenue. Furthermore, the advent of digitalised business models, although with considerable potential to improve trade in Africa, has greatly exacerbated the two central challenges…

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August 2020

A Simplified Method for Taxing Multinationals for Developing Countries: Building on the ‘Amount B’ Proposal to Repair the Transactional Net Margin Method

by Michael C. Durst

This paper considers whether the ‘Amount B’ proposal currently being negotiated in the Inclusive Framework, for the attribution of fixed remuneration for the ‘routine’ distribution and marketing activities of MNE affiliates, may offer a useful template for the re-working of the widely used ‘transactional net margin’ transfer pricing method (TNMM). The TNMM has for years…

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