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July 2020

The Appropriateness of International Tax Norms to Developing Country Contexts

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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How Can Governments of Low-Income Countries Collect More Tax Revenue?

Mick Moore & Wilson Prichard

Moore and Prichard provide two different kinds of answers to the question of how governments of developing countries can increase tax revenues. First, they discuss seven potential revenue sources that governments of developing countries tend to use less than they should. Mining, tobacco and alcohol, the incomes and wealth of rich people, and property are…

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July 2020

Thick claims and thin rights: Taxation and the construction of analogue property rights in Lagos

Tom Goodfellow & Olly Owen

The importance of tenure security for development and wellbeing is often reduced to questions about how titles can guarantee rights, overlooking the contested and layered nature of property rights themselves. We use the case of Lagos to analyse property rights as ‘analogue’ rather than ‘digital’ in nature – things that only exist by degree, where…

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July 2020

Tax Compliance of Wealthy Individuals in Rwanda

Jalia Kangave, Kieran Byrne & John Karangwa

Increasing emphasis is being placed on the need for low income countries to collect more tax revenue. In parallel, the need for equitable tax systems is also gaining prominence. While African countries have made remarkable progress in increasing tax collections, taxation in many African countries is inequitable in various respects. For example, many revenue authorities…

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July 2020

Who can make Ugandan Taxpayers more Compliant?

Ronald Waiswa, Doris Akol & Milly Nalukwago Isingoma

The rate of occurrence of tax evasion is higher in Uganda than in the rest of East Africa. Where the taxpayer has latitude to decide whether or not to be compliant, as in the case of income taxes, Ugandans seem to be less compliant than other East Africans. Uganda collects less in domestic taxes than…

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July 2020

Tax Compliance of Wealthy Individuals in Rwanda

Jalia Kangave, Kieran Byrne & John Karangwa

Low-income countries are increasing their fiscal independence through the improvement of domestic taxation systems. To continue to do so, they must ensure that these systems are perceived as equitable and preserve their integrity. An essential characteristic of an equitable tax system is the treatment of wealthy individuals. In this paper, we use key informant interviews…

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July 2020

Active Ghosts: Nil-filing in Rwanda

Giulia Mascagni, Fabrizio Santoro, Denis Mukama & Naphtal Hakizimana prepared by Adrienne Lees

Poor compliance is one of the key factors behind persistently low tax-to-GDP ratios in developing countries. Two dimensions of non-compliance that have been widely studied are under-reporting and non-filing (i.e. failing to submit a tax declaration altogether). However, there is a third and largely under-researched dimension of non-compliance: nil-filing. It refers to taxpayers who are…

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June 2020

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

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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June 2020

Review of Tax Treaty Practices and Policy Framework in Africa

Catherine Ngina Mutava

Tax treaties are agreements through which two countries agree to assign and restrict taxing rights on economic activities that span both countries. They were traditionally concluded mainly to avoid double taxation and create a favourable investment climate. However, in recent years, tax treaties concluded by sub-Saharan African countries – with OECD countries in particular –…

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June 2020

The Taxation of the Digitalised Economy: An African Study

Mustapha Ndajiwo

The advent of digitalised business models has considerable potential to improve trade in Africa, however, it has greatly exacerbated the two central challenges of international tax. The first challenge is the definition of taxable presence, and the second is the allocation of business profits of multinational enterprises (MNEs) among the different jurisdictions where they operate….

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