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

21 November 2019

Resource-Rich Countries and the Digital Tax Agenda

Alexandra Readhead

Those of us involved in the mining sector could be forgiven for thinking that the OECD’s program of work on…

18 November 2019

The Inclusive Framework is considering radical proposals, but in the real world…

Ben Dickinson

In her recent blog, Allison Christians usefully alerts us to some of the challenges and opportunities of the new rules…

5 November 2019

OECD Secretariat’s Unified Approach: How to get things on a truly Equal Footing

Allison Christians

The public consultation on the OECD Secretariat’s proposed “Unified Approach” to international corporate taxation ends on November 12th. Despite promises…

10 October 2019

The OECD’s digital tax proposal: untangling the impact of ‘Pillar One’ on developing countries

Martin Hearson

Yesterday the OECD secretariat published its proposed ‘unified approach’ to update corporate tax rules for the digital era, or at…

30 September 2019

Tax treaties: Why the Indonesian government keeps losing in court

Maarten Hietland

There is a growing interest in the role that double tax agreements play in eroding societies’ tax bases. While long…

29 August 2019

‘Marketing intangibles’: challenges and opportunities for taxation in Africa

Anthony Kibirige

Intangible assets are more valuable than ever before. The Global Intangible Finance Tracker found that 52% of the overall enterprise…

16 April 2019

Call for proposals: International taxation and development (Closed)

Context The international tax system is changing rapidly. We see substantial changes in both international tax ‘rules’ and in the…

20 February 2019

ICTD Annual Meeting in Kigali: “What Next for Tax Research in Africa?”

On February 5-8th, the International Centre for Tax and Development (ICTD) held its seventh annual meeting in association with the…

10 February 2019

ICTD Welcomes New Research Proposals (Call now closed)

The ICTD is now in a position to fund new research proposals on tax and development. We welcome all proposals…

1 November 2018

IDS & ICTD recruiting 2-3 Research Fellows

The ICTD is seeking to appoint two or three established researchers with expertise in taxation and development, who are able…

15 June 2018

TJN invites feedback on chapters about illicit financial flows

The Tax Justice Network has launched a project to create a collaborative, online book that seeks to provide a comprehensive…

10 May 2018

Submit your comments on two draft toolkits to help address profit shifting in the mining sector

The IGF together with the OECD invite comments on two draft toolkits that will help developing countries address profit shifting…

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

•

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).