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

10 August 2026

The UN Tax Convention draft protocol on cross-border services: clear direction but crucial details left open

Frederik Heitmüller

The much awaited Co-Lead’s draft protocol on the taxation of income from cross-border services was published on 20 July 2026….

4 August 2026

Double taxation relief on remote services – implications for UN Tax Convention Protocol 1 negotiations

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

To inform ongoing negotiations on the taxation of cross-border services at the UN, we wrote a study on double tax…

26 November 2025

A new era or business as usual? Why the UN Expert Committee on Tax is still relevant

Florian Dierich

The Committee’s most prominent contribution is the UN Model Tax Convention, which provides model language for the negotiation of bilateral…

4 November 2025

UN Tax Convention Reading List Part 3: Protocol 2 – Dispute Resolution and Prevention

Florian Dierich, Frederik Heitmüller

In Part 3 of our UN Tax Convention reading list, we bring together key research and analysis on dispute prevention…

31 October 2025

UN Tax Convention Negotiations: Where are we at and where are we headed?

Frederik Heitmüller, Florian Dierich

In preparation for the Nairobi session, two documents were shared for discussion: a Framework Convention Template prepared by the Co-lead…

8 October 2025

UN Tax Convention reading list part 2: Protocol 1 – Taxation of cross-border services

Florian Dierich, Frederik Heitmüller

The negotiations for Protocol 1 present a genuine opportunity to revisit how cross-border services are taxed. But, as we explored…

7 November 2019

ICTD Research Fellow Martin Hearson presents at WBG/IMF Tax Sunday

On October 20th, ICTD Research Fellow Dr Martin Hearson presented at the 6th annual World Bank Group and IMF “Tax…

6 November 2019

ICTD and South Centre host roundtable for developing countries at UN Tax Committee

ICTD Senior Fellow Sol Picciotto, Research Fellow Martin Hearson, and researcher Mustapha Ndajiwo participated in the recent UN Tax Committee…

17 October 2019

Developing countries at risk of being left behind in global tax reform, say researchers

Press Release Today, the G20 Finance Ministers are meeting in Washington D.C. to consider the OECD’s proposal for a “unified…

30 July 2019

Taxing the digitalising economy: A critical development challenge

The Institute of Development Studies asked us to reflect on the question: “What are the critical global challenges of our…

18 July 2019

ICTD convenes international workshop on tax challenges of the digitalisation of the economy

During 2019 and 2020, governments of over 130 countries, led by the OECD and G20, are considering radical reforms to…

7 May 2019

ICTD welcomes new Research Fellow Martin Hearson

The ICTD is pleased to welcome Martin Hearson to the team. He will be leading the ICTD’s research programme on…

Ukraine – global development and economic implications?

In person

16 March 2022 – 13:00

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Timezone: Europe/London

Institute of Development Studies, University of Sussex, Library Road, Falmer, Brighton, UK

Location: IDS Convening Space and online The world has been reeling in shock at the devastation being caused by the Russian invasion of Ukraine. Beyond the grave and urgent humanitarian needs for the people of Ukraine, and the millions now

New Tools for Tax Treaty Negotiation: Upcoming Webinars

Virtual

30 November 2021 – 14:00

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Timezone: Europe/London

The use of tax treaties by developing countries is controversial, to say the least. Best case scenario? Tax treaties help to attract foreign direct investment by reducing the risk of double taxation. Evidence for this is weak. Worst case scenario?

At the table, off the menu?

Virtual

18 December 2020 – 13:00

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Timezone: Europe/London

Institute of Development Studies, University of Sussex, Library Road, Falmer, Brighton, UK

A virtual roundtable discussion on deepening the inclusiveness of global tax negotiations. Since 2013, the formal structure of global corporate tax policymaking has changed. Decisions are no longer made by 37 OECD members, but by 137 countries from all regions

Taxing Africa book launch at the University of Toronto

25 September 2018 – 18:00

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Munk School of Global Affairs and Public Policy, Bloor Street West, Toronto, ON, Canada

The Munk School of Global Affairs and Public Policy is hosting a launch of our book Taxing Africa: Coercion, Reform and Development. The event will be held on Tuesday September 25th from 6:00 – 8:00pm in the Round Room on