The International Tax Regime Complex: Understanding Change in Global Tax Governance
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Research in Brief 162
Following a landmark vote in the UN General Assembly in December 2023, negotiations are under way to establish a UN Framework Convention on tax. While the UN already plays a role in international tax cooperation, this convention’s scope extends beyond its existing mandate and into policy areas where the OECD has historically held sway. This introduces potential risks, including duplication of effort and competition between institutions, and incoherence in international tax policy. However, it is not certain that these risks will materialise. The ultimate outcome will depend on interactions between states and institutions, and between institutions themselves. We use insights from international relations scholarship to explore the main drivers, enablers and constraints on changes to the status quo.
Katharina Kuhn is a PhD Candidate at the London School of Economics’ Department of International Relations. She holds a BA in Political Science, Sociology and Religious Studies from the University of Würzburg, and an MSc in Global Governance and Diplomacy from the University of Oxford. Katharina researches the factors that shape the international tax policy of developing states, with a particular focus on their participation in the OECD/G-20 BEPS Project.
Lucinda Cadzow is a Fellow in International Political Economy (IPE) in the International Relations Department at LSE. Prior to joining LSE, Lucinda obtained a DPhil in International Relations at the University of Oxford, an MPhil in International Relations from the University of Oxford, and a Bachelor of Arts (Honours) at Monash University in Melbourne.
Frederik Heitmüller is an Associate Postdoctoral Fellow with ICTD’s International Tax Team. His research focuses on policies against corporate tax avoidance, the influence of international norms in the Global South and global tax governance. He is also an independent consultant on tax policy.
Prior to joining ICTD, he obtained a PhD from Leiden University, Netherlands, where he investigated the political economy of the BEPS Project in the Global South as member of the GLOBTAXGOV project, and taught courses on international and comparative taxation. He has a master’s degree in political science from Sciences Po Bordeaux and University of Stuttgart.
Martin Hearson is a Research Fellow at IDS, 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 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.
Citation: Kuhn, K.; Cadzow, L.; Heitmüller, F.; Hearson, M. and Randriamanalina, T. (2025) The International Tax Regime Complex: Understanding Change in Global Tax Governance, ICTD Research in Brief 162, Brighton: Institute of Development Studies, DOI: 10.19088/ICTD.2025.034
