FACTI Background Paper 3

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 for applying these norms to the digitalising economy.


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.

Joy W. Ndubai

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.