Research Theme

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.

ICTD has also been closely following the developments around the UN Tax Convention. Check out our latest research and analysis here.

Led By

Martin Hearson

Key Resources

Working Paper

Global Rules, Local Realities: Lessons from the Global South on International Tax Standards

June 2026

Martin Hearson, Frederik Heitmüller, Florian Dierich

Working Paper

Scenarios for Negotiating a UN Framework Convention on International Tax

January 2025

Frederik Heitmüller

Partner Publication

A Fairer Global Tax Architecture

September 2024

Martin Hearson, Frederik Heitmüller, Mbakiso Magwape, Suranjali Tandon

Journal Article

Relieving Double Taxation on Cross-Border Services: A Comparative Analysis of Major Exporting Countries

July 2026

Frederik Heitmüller, Aisha Aize Isa, Florian Dierich, Yvette Nakibuule Wakabi

International Tax Library

Book

Taxing Multinational Enterprises as Unitary Firms

March 2017

Sol Picciotto

Working Paper

Tax Base Erosion and Profit Shifting in Africa – Part 2: A Critique of Some Priority OECD Actions from an African Perspective

February 2017

Annet Oguttu

Working Paper

Transfer Pricing in Argentina 1932-2015

January 2017

Veronica Grondona, Andres Knobel

Research in Brief

Improving International Tax Dispute Settlement

January 2017

Sol Picciotto

Policy Brief

What Have We Learned About International Tax Disputes?

December 2016

Sol Picciotto

Working Paper

International Tax Disputes: Between Supranational Administration and Adjudication

August 2016

Sol Picciotto

Working Paper

Tax Base Erosion and Profit Shifting in Africa – Part 1: Africa’s Response to the OECD BEPS Action Plan

June 2016

Annet Oguttu

Working Paper

Taxing Multinational Enterprises as Unitary Firms

June 2016

Sol Picciotto

Policy Brief

International Corporate Taxation

May 2016

Sol Picciotto

Journal Article

Could changes in the international tax system be a strategy for dealing with inequality?

May 2016

Mick Moore

Working Paper

A Review of Uganda’s Tax Treaties and Recommendations for Action

April 2016

Martin Hearson, Jalia Kangave

Working Paper

Measuring Tax Treaty Negotiation Outcomes: The ActionAid Tax Treaties Dataset

February 2016

Martin Hearson

29 November 2018

China’s challenge to international tax rules

Martin Hearson, Wilson Prichard

States are currently struggling to reach global agreement on the taxation of digital firms such as Apple and Google, suggesting…

1 August 2018

Tax Justice – How to integrate local experiences into an international campaign?

Mª Josep Cascant-Sempere (Kas)

What does tax justice mean at the local level, and how can the experiences of informal market traders be linked…

10 May 2018

Why illicit financial flows and multinational tax avoidance are not the same thing

Maya Forstater

Professor Sol Picciotto recently wrote an article which responds to a paper I wrote on the question of what is…

10 May 2018

Why tax avoidance is illicit

Sol Picciotto

In a recent paper, revised and published as a blog post, I argued that tax avoidance by multinationals should be…

2 May 2018

When Does Beneficial Ownership Transparency Improve Revenue Collection? Three Considerations for Developing Countries

Wilson Prichard

Recent years have witnessed an accelerating push to expand access to information on the beneficial ownership of corporate entities, in…

22 March 2018

A withhold up in Mongolia? Thoughts on the renewed tax debate around Oyu Tolgoi

Alexandra Readhead, David Mihalyi

This piece is available in Mongolian here. Governments of mining countries are vulnerable to investors using double tax agreements (DTAs)…

21 September 2026

Call for Papers: Research workshop on the UN Framework Convention on International Tax

Frederik Heitmüller, Martin Hearson

With only one year to go, the negotiations on the UN Framework Convention on International Tax Cooperation and its…

27 July 2026

ICTD launches report on 15 years of research and the future of development finance

The International Centre for Tax and Development (ICTD) has officially released its major report, Taxing Smarter: Advancing Reform Through Research…

29 June 2026

New ICTD research shows uneven adoption of international tax standards by lower-income countries

Martin Hearson, Frederik Heitmüller

This paper by Martin Hearson, Frederich Heitmüller and Florian Dierich, draws together findings across all seven country case studies, identifying…

20 March 2026

Tax treaties in spotlight as UN Tax Convention negotiations deepen

Martin Hearson, Frederik Heitmüller, Florian Dierich

When member-states convene in New York this August for the fifth substantive session on the UN Framework Convention on International…

30 January 2025

UN Tax Talks: New research highlights key scenarios at next week’s historic negotiations

Martin Hearson, Frederik Heitmüller

New research from the International Centre for Tax and Development (ICTD) provides crucial insights into the challenges and opportunities shaping…

19 November 2024

G20 Brazil: How does taxation fit into the agenda?

Fabrizio Santoro, Vanessa van den Boogaard, Martin Hearson, Max Gallien, Frederik Heitmüller

Researchers from the International Centre for Tax and Development (ICTD) participated in crafting such recommendations in a number of policy…

Webinar: Comparative perspectives on international tax from the global South

Virtual

7 July 2026 – 14:00

•

Timezone: Europe/London

This webinar launches the ‘Comparative Perspectives on International Tax from the Global South’ project, started by the International Centre for Tax and Development (ICTD), in 2024. The project examines how governments in seven countries — Ghana, Kenya, Nigeria, Pakistan, Peru,

Webinar: Four definitions to change the world webinar series – Foreseeable relevance

Virtual

29 May 2026 – 13:00

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Timezone: Europe/London

The panel will evaluate current instruments and frameworks, their merits, and their limitations in order to contribute to the development of an exchange of information regime that is inclusive and universal.

Webinar: Protocol 1 in focus – progress and the way forward

Virtual

17 March 2026 – 14:00

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Timezone: Europe/London

This webinar will give you a clear picture of where things stand and what comes next on the UN Tax Convention Protocol 1 on cross-border services taxation.

Tax Dispute Resolution Under the UN Convention on Tax: Lessons from Investment Arbitration

Virtual

11 February 2026 – 18:15

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Timezone: Europe/London

ICTD Associate Postdoctoral Fellow Frederik Heitmüller will be speaking at a panel about the tax dispute resolution under the UN Framework Convention on International Tax, hosted by the International Institute for Sustainable Development (IISD).