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.

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Publications:

January 2022
The Rise of China and Contestation in Global Tax Governance
by Martin Hearson & Rasmus Corlin Christensen

This paper examines the relationship between China’s changing economy and its global business tax diplomacy. Three trends dominate: China is becoming a net capital exporter, emerging as a major consumer market, and is home to digital giant firms including Baidu, Tencent and Alibaba. The resulting drive to promote both ‘going out’ and ‘bringing in’ foreign…

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January 2022
The Politics of Taxing Multinational Firms in a Digital Age
by Martin Hearson & Margarita Gelepithis

Taxing multinationals is politically difficult because of the structural power of mobile firms within the global economy, and this structural power is expected to increase in the digital age. Recently however there has been a breakdown in the international corporate tax consensus that structured tax competition over the past century. A new norm of international…

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December 2021
Taxing Profits From International Transport In Africa: Past, Present and Future of Article 8 (Alternative B) of the UN Model
by Bob Michel & Tatiana Falcao

International maritime shipping is an essential part of global business. Since the establishment of the current international tax regime in the 1920s, there has been a consensus that profits generated by this business are taxable only in the residence state –the state where the shipowners are located. Source states – the port states where business…

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December 2021
Tax Treaties and Enterprise Outcomes: Evidence Across Developing African Countries
by Uchenna Efobi & Oluwabunmi O. Adejumo

Studies have noted the possibility of tax treaties constraining the tax policy autonomy of developing countries, while their impact on enterprise development within host economies remains an empirical issue. This study examines the effects and heterogeneous differences in estimated effects of tax treaties on small businesses in developing countries that agree to these agreements. The…

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November 2021
Taxing Profits from International Maritime Shipping in Africa: Past, Present and Future of UN Model Article 8 (Alternative B)
by Bob Michel & Tatiana Falcão

International maritime shipping is an essential part of global business. Since the establishment of the current international tax regime in the 1920s, there has been a consensus that profits generated by this business are taxable only in the residence state – the state where the shipowners are located. Source states – the port states where…

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November 2021
Tax Treaty Aggressiveness: Who is Undermining Taxing Rights in Africa?
by Lucas Millán-Narotzky, Javier García-Bernardo, Maïmouna Diakité & Markus Meinzer

Tax avoidance strategies by multinational companies rely heavily on tax treaties. Multinational companies can relocate financial activities across countries to ensure the applicability of the most beneficial tax treaties. This ‘treaty shopping’ can be particularly harmful to African countries, impairing their efforts for domestic resource mobilisation and achieving sustainable development goals. In this paper, we…

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September 2021
The Politics and History of Global Tax Governance
by Martin Hearson & Thomas Rixen

We discuss the history, political determinants and current challenges of global tax governance. We divide the last century into three eras: foundation, during which states built a regime to prevent double taxation using bilateral treaties and soft multilateral coordination; stability, during which this regime failed to adapt to the growth in volume and complexity of…

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Using New Data to Support Tax Treaty Negotiation
by Martin Hearson, Marco Carreras & Anna Custers

This paper introduces the new Tax Treaties Explorer dataset, developed with support from the World Bank and the G-24, and illustrates its use for research by tax treaty negotiators, policy makers, and researchers. The new dataset provides a rich source of data to reexamine existing tax treaty policy, inform negotiation positions, and assess treaty networks….

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July 2021
The Contested Shaping of International Tax Rules: The Growth of Services and the Revival of Fractional Apportionment
by Sol Picciotto

The digitalisation of the economy has spotlighted fundamental flaws in international tax rules, which have been exacerbated since the 1970s with the wider shift to the services economy and the growth of international services. These systemic flaws have been more evident from the perspective of countries that are mainly importers of services that have tried…

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Tax Treaties of G-24 Countries: Analysis Using a New Dataset
by Martin Hearson

Between them, the G-24 countries have over 800 bilateral tax treaties in force. Each treaty limits states’ ability to tax income earned within their borders by investors and service providers from the treaty partner. As well as constraining states’ ‘taxing rights’, they are also vulnerable to abuse through ‘treaty shopping’. A new dataset of developing…

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Blogs:

March 2022
by Giulia Mascagni & Mick Moore

Last week, the Institute of Development Studies (IDS) held an event on the global development and economic implications of the conflict in Ukraine, at which ICTD Fellows Mick Moore and Giulia Mascagni spoke on the subject of sanctioning Russian oligarch’s wealth, the menace of the offshore financial system, and the urgent need and opportunity to…

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February 2022
by Didier Jacobs

Last October, 137 of the 140 jurisdictions that are members of the Inclusive Framework reached a high-level agreement on the taxation of multinational corporations, combining a reallocation of taxing rights to market countries (Pillar 1) and a 15% global minimum effective tax rate (Pillar 2). The agreement builds on proposals developed by the OECD, a…

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November 2021
by Martin Hearson

G20 leaders are celebrating a new agreement to strengthen the taxation of tech firms and create a global minimum tax, reached by 136 jurisdictions and brokered at the OECD. Numerous lower-income countries have expressed frustration that their influence was marginal and their demands rejected, but many have nonetheless signed up. Historical legacies These negotiations reflect…

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Research Projects:

Past Project
National Authority and Contestation in Global Tax Governance: Transfer Pricing Regulations in Sub Sahara Africa
Project Researchers: Cassandra Vet & Danny Cassimon

This project revolves around the question of how OECD transfer pricing regimes gained national authority on the intersection of a global push for harmonisation and the questionable efficacy of national transfer pricing audits. This way, the project brings relevant knowledge on the emergence, authority and efficiency of the SSH-African regimes to support the development of…

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Past 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
Tax Treaty Aggressiveness: Who is Undermining Taxing Rights in Africa?
Project Researchers: Markus Meinzer, Maimouna Diakite, Lucas Millan & Mirsolav Palansky

Tax avoidance strategies by multinational companies rely heavily on tax treaties. Multinational companies can relocate financial activities across countries to ensure the applicability of the most beneficial tax treaties. This ‘treaty shopping’ can be particularly harmful to African countries, impairing their efforts to mobilise domestic revenues. This research project will analyse the extent to which…

Project Outputs

Working Paper
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Past 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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