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

Working Paper

Developing Country Revenue Mobilisation: A Proposal to Modify the ‘Transactional Net Margin’ Transfer Pricing Method

January 2016

Michael Durst

Working Paper

Measuring Misalignment: the Location of US Multinationals’ Economic Activity Versus the Location of their Profits

November 2015

Alex Cobham, Petr Janský

Working Paper

A Price-Based Royalty Tax?

October 2015

Kimberly A. Clausing, Michael Durst

Working Paper

Limitations of the BEPS Reforms: Looking Beyond Corporate Taxation for Revenue Gains

September 2015

Michael Durst

Research in Brief

Is the International Tax System Fit for Purpose, Especially for Developing Countries?

September 2015

Sol Picciotto

Unitary Taxation in Federal and Regional Integrated Markets

September 2015

Erika Dayle Siu

Lessons for International Tax Reform from the US State Experience under Formulary Apportionment

September 2015

Kimberly A. Clausing

Working Paper

Limitations on Interest Deductions: A Suggested Perspective for Developing Countries

September 2015

Michael Durst

Working Paper

Unitary Taxation in the Extractive Industry Sector

September 2015

Erika Dayle Siu, Sol Picciotto, Jack Mintz, Akilagpa Sawyerr

Working Paper

Unitary Taxation: Tax Base and the Role of Accounting

September 2015

Prem Sikka, Richard Murphy

Working Paper

The Tax Policy Outlook for Developing Countries: Reflections on International Formulary Apportionment

September 2015

Michael Durst

Working Paper

Global Taxes and International Taxation: Mirage and Reality

September 2015

Richard M. Bird

22 May 2024

What to do with a global majority: making the most of a UN tax convention

Martin Hearson

The negotiations on ‘Pillar One’ at the G20/OECD Inclusive Framework have shown quite how much effort governments are willing to…

21 February 2024

The right to tax: can Customs Duties on Electronic Transmissions be a turning point for developing countries?

Karishma Banga

It is a historic moment for international trade negotiations; at the World Trade Organization’s (WTO) 13th Ministerial Conference (MC13) this…

12 January 2024

The Subject-To-Tax-Rule (STTR) – which one to choose?

Frederik Heitmüller

A subject-to-tax rule (STTR) is a tax treaty provision that allows source countries to impose an additional tax liability on…

14 December 2023

The UN Tax Committee spreads its wings

Sol Picciotto

After attending the United Nations Tax Committee meeting in October and participating in its deliberations, Professor Sol Picciotto reflects in…

1 December 2023

A new UN Tax convention – how will it change global tax governance?

Martin Hearson

Last week, the United Nations General Assembly passed a historic resolution commencing work on a UN tax convention. For decades,…

27 July 2023

Prescriptive approaches to taxation: Reclaiming policy space

Irene Musselli

Low-income countries with limited taxation capacity and expertise require simple and context-specific methods to combat commodity trade mispricing and related…

19 January 2023

Call for Applications: Four fully-funded PhD scholarships in tax and development

The International Centre for Tax and Development (ICTD) is a research centre aiming to improve tax policy and administration in…

1 August 2022

Call for abstracts: Research colloquium on global tax governance

GLOBTAXGOV and the ICTD are inviting submissions of abstracts to discuss early-stage original research for the fourth season of the…

12 July 2022

Job Opportunity: Post-Doctoral Researcher (International Tax)

Closing date for applications: Sunday 21st August 2022…

13 April 2022

Job Opportunity: Senior Communications Consultant, DIGITAX Programme

Closing date for applications: May 8th, 2022 The International Centre for Tax and Development (ICTD) is looking to hire a…

28 January 2022

Call for abstracts: Research colloquium on global tax governance

After the first two successful seasons of the research colloquium on global tax governance co-organised by GLOBTAXGOV and Martin Hearson…

8 December 2021

Launch of the Tax Treaties Explorer: New Data for Better Negotiation

Tax Treaties and Developing Countries The use of tax treaties by developing countries is controversial: Best case scenario? Tax treaties…

Webinar: Comparative perspectives on international tax from the global South

Virtual

7 July 2026 – 14:00

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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).