Showing 1 - 12 of 79 publications

Developing influence: the power of ‘the rest’ in global tax governance

by Martin Hearson, Rasmus Corlin Christensen & Tovony Randriamanalina

As Western-led institutions of global governance adapt to global power shifts, the question of which countries dominate, and how, increasingly animates scholarship. Yet while attention has shifted from ‘Great’ to ‘Rising’ Powers, the underlying focus on market power has changed little. In this article, we shift the focus to alternative forms of power that developing…

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April 2022

Grounding ActionAid’s Tax Justice Campaigns in Nigeria

by Ma Josep Cascant-Sempere

Integrating the demands raised by those most affected by poverty into international campaigns is important for safeguarding ethical integrity and encouraging mobilization. This article examines the case of the international non-governmental organization (INGO) ActionAid, which managed, although not without challenges, to integrate the tax complaints of market traders — such as multiple taxation — into…

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January 2022

The Rise of China and Contestation in Global Tax Governance

by Martin Hearson & Rasmus Corlin Christensen

This paper examines the relationship between China’s changing economy and its global business tax diplomacy. Three trends dominate: China is becoming a net capital exporter, emerging as a major consumer market, and is home to digital giant firms including Baidu, Tencent and Alibaba. The resulting drive to promote both ‘going out’ and ‘bringing in’ foreign…

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December 2021

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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September 2021

The Politics and History of Global Tax Governance

by Martin Hearson & Thomas Rixen

We discuss the history, political determinants and current challenges of global tax governance. We divide the last century into three eras: foundation, during which states built a regime to prevent double taxation using bilateral treaties and soft multilateral coordination; stability, during which this regime failed to adapt to the growth in volume and complexity of…

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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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