The ICTD has since 2013 supported a number of research projects and programs on international tax issues relevant to developing countries. The ICTD is now beginning a new phase of this work, with initial funding from the Bill and Melinda Gates Foundation, which it is hoped will be supplemented from other sources, and may be extended. ICTD is seeking to appoint a researcher, initially at least under a consultancy contract, and for 12-18 months. The person appointed would work with and under the direction of Prof. Sol Picciotto, ICTD Senior Fellow, and be ultimately responsible to Prof. Mick Moore, CEO of the ICTD.
We are looking for someone with qualifications, knowledge and some experience in international corporate taxation, especially in relation to developing countries. The minimum qualification is a Master’s with specialisation in international tax. Preference will be given to candidates with additional completed research, either a PhD, or research-based reports, and/or professional work in a revenue authority or tax advisory firm. Candidates should also have some knowledge of recent policy debates and work, especially relating to tax treaties and the G20/OECD project on base erosion and profit shifting (BEPS). All candidates should be able to demonstrate an ability to conduct research in this field, and to write a high quality report or paper in English. The person appointed ideally should be a citizen of an African country, and either resident in Africa or willing to spend extended periods there.
The candidate will:
(i) carry out his/her own research, most likely on tax treaty policies in Africa;
(ii) develop contacts with researchers in revenue authorities, academia and civil society in Africa to stimulate and support their research (building on ICTD’s existing links), and
(iii) organise seminars or workshops in Africa to present and discuss ICTD and related research.
The work to be undertaken will fall under two headings:
1. Beyond BEPS
ICTD researchers have tracked the BEPS project since its launch in 2013 through to delivery of the 13 reports on its 15 action areas in October 2015. The BEPS project has now moved to the implementation phase, although there is continuing work in some key areas (including tax implications of the digitalised economy), and a large number of developing countries are expected to join the Inclusive Framework as BEPS Associates. Implementation involves significant changes to tax treaties, to be coordinated through a multilateral instrument open to all states, as well as many recommended or suggested changes to domestic laws. ICTD research will continue to focus on evaluation of these proposals from a developing country perspective, as well as exploring alternatives for both short- and medium-term. Alternatives include issues under consideration by other bodies, notably the UN Committee of Tax Experts, and the African Tax Administration Forum. Specific projects to be undertaken will depend to some extent on the changing policy landscape, as well as input from ICTD partners and stakeholders. Based on our previous work, some projects are ready to start, some are likely, and others identified as possibilities.
The immediate projects are:
(a) a Handbook on key international tax issues for developing countries, to be written by ICTD Senior Fellow Michael Durst;
(b) work on aspects of implementation by developing countries of BEPS project outcomes, conducted and/or coordinated by ICTD Senior Fellow Prof. Sol Picciotto; this will include (i) the BEPS multilateral instrument, (ii) measures for preventing and resolving international tax disputes, and (iii) methods for dealing with transfer pricing suitable for developing countries.
Likely or possible topics include:
(c) application and administration by developing countries of anti-abuse rules and measures, both in treaties and domestic law, and their interaction;
(d) measures to protect the source tax base, in particular taxation of cross-border services (including digitalised delivery);
(e) specific issues relating to sectors particularly important to developing countries, especially telecommunications and extractive industries (since work in these areas is being done by a number of other bodies, the ICTD will continue to contribute in these only on targeted issues where it can add value);
(f) international or regional measures to control negative spill-overs resulting from tax incentives.
2. Tax Treaty Policies
The BEPS project involved a major shift of emphasis, to ensure that tax treaties should not only prevent double taxation, but also double non-taxation. This will require some significant changes in both the legal content of tax treaties and their administration. A number of developing countries have already been re-evaluating their tax treaty networks (e.g. Uganda), while some key OECD countries have conducted reviews of their treaties with developing countries (e.g. Ireland, the Netherlands). This was not a priority issue for ICTD in its first phase, but has been identified as important now. A first step has already been taken earlier this year, when the ICTD agreed to host a Tax Treaties dataset developed by Action Aid International, and published a working paper describing it and identifying some key trends.
It is proposed to build on this through the following work:
(g) quantitative and qualitative analysis of tax treaty provisions and their effects on both tax revenues and investment flows, using and extending the ActionAid/ICTD tax treaty database, as well as other sources.
The level of remuneration, depending on qualifications and experience, will be in the range of $160 - $220 per working day. The researcher would also have access to a budget for necessary travel in connection with the research. The number of days to be worked will be specified in work packages agreed between the researcher and ICTD, which will also state milestones and deliverables. Payments will be made on approval and commencement of each work package, and on satisfactory completion of the milestones and deliverables.