Working Paper 115

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 observers have emphasised that developing countries in particular face practical obstacles that lead to unequal participation in practice. In this paper, we assess these claims, drawing primarily on 48 interviews with negotiators, policymakers and stakeholders involved in global tax discussions. We find that the explosion in formal membership has not in itself led to the step-change in developing country influence that the raw numbers imply. This is because of a combination of structural obstacles that are not unique to the IF, and some challenging aspects of the OECD’s way of working. Yet, lower-income countries have made some modest achievements to date, and there are signs of incremental progress towards a more effective presence. We develop a typology of mechanisms through which successes have been achieved: association with the efforts of more powerful states, anticipation of lower-income countries’ needs by the OECD secretariat and others, collaboration to form more powerful coalitions, and the emergence of expert negotiators with individual authority.


Rasmus Corlin Christensen

Rasmus Corlin Christensen's main research interest is in the political and professional foundations of the rules and practices of international taxation. He is a Postdoctoral researcher at the Copenhagen Business School and a Research Associate of the ICTD.

Martin Hearson

Martin Hearson is a Research Fellow at IDS, co-Research Director of the ICTD and the International Tax programme lead. His research focuses on the politics of international business taxation, and in particular the relationship between developed and developing countries. Before joining ICTD, Martin was a fellow in international political economy at the London School of Economics and Political Science, teaching courses on political economy and global financial governance.

Tovony Randriamanalina

Tovony Randriamanalina has a PhD in International Tax Law from the University of Paris-Dauphine. Prior to her academic work, she was a Tax Official at the Malagasy Revenue Authority and is a graduate of the National School of Administration of Madagascar. She researches the appropriateness of the transfer pricing rules for the particular case of developing countries. Her presentation on this topic won the prize for the best student paper of the ATAF/ATRN inaugural conference of the African Tax Research Network on 2015.