International Tax

Low-income countries are more dependent on corporate income tax revenue than richer countries, and at the same time, disproportionately affected by multinational tax avoidance. Our research on this theme investigates ways in which developing countries can protect their tax bases, including through simplified transfer pricing methods and improved tax treaty policies. It also examines the challenges and opportunities developing countries face from their participation in international tax negotiations.

Publications:

Addressing the Challenges of Taxation of the Digital Economy: Lessons for African Countries
by Solomon Rukundo

The rapid growth of the digital economy in many African countries poses serious challenges to traditional tax regimes. Revenue authorities must protect their revenue base without hindering the development and use of new technologies or the business community’s involvement in the e-marketplace. Two international taxation rules pose a challenge to taxing the global digital economy….

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January 2020
Corporate Tax Negotiations at the OECD: What’s at Stake for Developing Countries in 2020?
by Martin Hearson

We could be in the midst of the biggest change to the way multinational companies are taxed in decades. In January 2019, over 130 developed and developing countries committed to ‘go beyond’ some of the fundamental principles that have underpinned cooperation on corporate taxation for a century (OECD 2019a). They opened negotiations to redistribute ‘taxing…

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January 2020
Addressing the Challenges of Taxation of the Digital Economy: Lessons for African Countries
by Solomon Rukundo

The rapid growth of the digital economy in many African countries has led to concerns about whether their tax regimes are equipped to deal with this new phenomenon. The shift from a traditional bricks and mortar commercial environment to one that is electronic and information-based poses serious and substantial challenges to traditional tax regimes. African…

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December 2019
Review of Tax Treaty Practices and Policy Framework in Africa
by Catherine Ngina Mutava

In recent years, tax treaties concluded by sub-Saharan African countries have become more residence-based with fewer provisions allocating taxing rights to the source countries. This trend is observed in treaties signed with OECD countries in particular. For countries which are capital importers, as is the case with most African countries, this means that these countries…

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August 2019
Safe Harbour Regimes in Transfer Pricing: An African Perspective
by Alexander Ezenagu

Applying transfer pricing rules in Africa poses great difficulties. There are few reliable comparables to benchmark prices and terms fixed by related entities in their transactions with each other. This means that jurisdictions struggle with applying the arm’s length principle in intra-firm dealings, as prescribed by tax treaties and domestic laws. Furthermore, the requirement for…

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Safe Harbour Regimes in Transfer Pricing: An African Perspective
by Alexander Ezenagu

The global consensus to treat multinational enterprises (MNEs) as separate entities for tax purposes requires them to act at arm’s length in the transfer of goods and services, especially setting the prices of such transfers. This means that, although in practice they are integrated entities under the ownership and control of a parent company, operating…

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The New Politics of Global Tax Governance: Taking Stock a Decade After the Financial Crisis
by Rasmus Corlin Christensen & Martin Hearson

The financial crisis of 2007–2009 is now broadly recognised as a once-in-a-generation inflection point in the history of global economic governance. It has also prompted a reconsideration of established paradigms in international political economy (IPE) scholarship. Developments in global tax governance open a window onto these ongoing changes, and in this essay we discuss four…

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February 2019
Taxing Multinational Business in Lower-Income Countries: Economics, Politics and Social Responsibility
by Michael C. Durst

The world’s lower-income countries face an urgent need for public revenue to build social and economic infrastructure. These countries, however, face a dilemma in seeking to tax the income of multinational companies operating within their borders. On the one hand, because lower-income countries face substantial limitations on their ability to raise revenue from broad-based taxes…

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November 2018
China’s Challenge to International Tax Rules and the Implications for Global Economic Governance
by Martin Hearson & Wilson Prichard

Twentieth century institutions of global economic governance face a profound challenge adapting to the rise of emerging markets and, especially, China’s rise. This is especially the case for the international tax regime, whose institutional home is the OECD and which is based on norms that favour capital exporting states. To understand the nature of the…

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November 2018
Problems of Transfer Pricing and Possibilities for its Simplification
by Sol Picciotto

This ICTD Research in Brief is a two-page summary of ICTD Working paper 86 by Sol Picciotto. This series is aimed at policy makers, tax administrators, fellow researchers and anyone else who is big on interest and short on time. The international system for taxation of the profits of multinational enterprises (MNEs) is deeply dysfunctional….

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Blogs:

May 2020
by Alexander Ezenagu, Alexandra Readhead, Allison Christians, Anthony Kibirige, Catherine Ngina Mutava, Joy Ndubai, Lakshmi Narayanan, Mike Durst, Mustapha Ndajiwo & Sol Picciotto

The OECD secretariat recently proposed a “stock taking exercise” to “re-examine how international tax rules currently meet the needs of developing countries” leading potentially to a “new deal on international taxation as part of the international effort to rebuild economic life in the post Covid-19 era.” The OECD’s Pascal Saint-Amans has suggested that this may…

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May 2020
by Rasmus Corlin Christensen

In the wake of the global financial crisis of 2007-08, tax havens became a hot topic as political leaders zeroed in on exotic, low-tax jurisdictions as sources of fiscal instability that exacerbated the crisis. With the Covid-19 pandemic, tax havens have been even more immediately and strongly linked to the crisis and the prospects for…

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April 2020
by Rasmus Corlin Christensen

Hour for hour, day for day, the world is changing due to the rapid spread of the coronavirus (Covid-19). Every area of social action is affected by the increasing restrictions being placed on citizens around the world through isolation and quarantines, posing profound problems for economies and policy-makers. Global negotiations over a new resolution to…

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Research Projects:

Current Project
Tax Treaties and High Growth Entrepreneurship: Firm-Level Evidence across Developing African Countries
Project Researchers: Uchenna Efobi, Covenant University & Oluwabunmi Adejumo

This research sets out to answer two main research questions. They include: What is the impact of Ratified Tax Treaties on small business development in the African region? Are there heterogeneous differences in this impact when considering the treaty partner, the type of treaty, and the proportion of foreign ownership of small businesses in the…

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Current Project
Double Tax Treaty Aggressiveness: Who is bringing down withholding taxes in Africa?
Project Researchers: Markus Meinzer, Maimouna Diakite, Lucas Millan & Mirsolav Palansky

This paper asks two interrelated questions, one focusing on a substantive issue, and the other focusing on methodological issues. First, what countries are most aggressive in clipping taxing rights through tax treaties in Africa? Second, how sensitive are the findings to different measures of treaty content and aggressiveness? In the context of efforts to mobilise…

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Current Project
Effective Tax Rates of Multinational Enterprises in Low- and Middle-Income Countries: Evidence from Country by Country Reporting
Project Researchers: Petr Janský & Javier García Bernardo

This project will look at the economic activities and taxes reported by large US MNCs in low- and middle-income countries – in contrast with other countries and other data sources. The researchers will present all the information in a paper that could be published in an ICTD working paper series and submitted to a leading…

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Past Project
Taxing international shipping in Africa: the source taxation alternative
Project Researchers: Tatiana Falcao, European University Institute & Bob Michel

The central question we want to address is whether African countries should consider taxing profits from international shipping derived by non-resident shipping companies and which are the policy options available for them to do so. We believe the question fits in with current calls in international tax demanding for the re-evaluation of the century-old rules…

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