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. Our work on this theme also includes examination of the OECD’s Base Erosion and Profit Shifting (BEPS) process from the perspective of developing countries, as well as exploring alternative methods of taxing multinational companies, namely unitary taxation.
Publications:
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…
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…
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….
The defects in the rules for allocation of the income of transnational corporations (TNCs) are at the heart of the current crisis in international corporate taxation. This paper explains how these rules emerged and developed, becoming increasingly complex, as they have shifted from a general concern to ensure a fair and reasonable allocation of the…
With the OECD issuance in June 2018 of its final guidance on the profit split method, individual countries must determine how they might consider and apply the profit split method (PSM) going forward. The OECD guidance issued reflects a consensus view that included input from the very large number of countries. The need for consensus…
Taxing Africa is an accessible and comprehensive introduction to the crucial debates around taxation and development in Africa. Taxation has been seen as the domain of charisma-free accountants, lawyers and number crunchers – an unlikely place to encounter big societal questions about democracy, equity or good governance. Yet it is exactly these issues that pervade…
Recent years have witnessed an accelerating push to expand access to information on the beneficial ownership of corporate entities, in an effort to bring greater transparency to multinational corporation (MNC) tax strategies, identify personal tax-evading wealth held overseas and combat global networks of criminality and corruption. This effort remains in its infancy, but has made…
This paper explores how the international donor community might most productively offer technical assistance to developing countries in the area of taxation, in light of the OECD’s recently completed study of ‘base erosion and profit shifting’ (BEPS). The paper addresses both the political and the technical constraints facing developing country tax administrations. It recommends that…
It is widely believed that the governments of many low-income countries, and especially the relatively poor performers, should be aiming to increase the proportion of GDP they raise in tax revenue. There are risks in emphasising increasing revenue at the expense of other objectives. Governments also need to be concerned with questions of equity, efficiency,…
A large proportion of international trade in goods and services is conducted between what are known technically as related parties. In practice, most of this trade is between different companies forming part of the same transnational corporate grouping. This is typically highly integrated in economic and financial terms, while legally appearing as a set of…
Blogs:
Just over a week ago, the Kenyan High court declared the double tax avoidance (DTA) agreement between Kenya and Mauritius unconstitutional. Here are some thoughts from two of our experts on the topic: Reflections from Catherine Ngina Mutava The ruling on the legality of the Kenya-Mauritius DTA presents an interesting situation. First, the declaration that…
The international tax event of the year took place on the 13-14th of March in Paris. It was the public consultation on Tax Challenges of Digitalisation of the Economy, organised for the Inclusive Framework on BEPS (Base Erosion and Profit Shifting), by the Organisation for Economic Cooperation and Development (OECD). For those who could not…
States are currently struggling to reach global agreement on the taxation of digital firms such as Apple and Google, suggesting that an international regime characterised by impressive coherence over a century may be beginning to fragment. While work on the politics of the international tax regime is still largely preoccupied with the US, a ‘great power’, this fragmentation largely…