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

Research in Brief

Is Transparency Enough? An Examination of the Effect of the Extractive Industry Transparency Initiative (EITI) on Accountability, Corruption and Trust in Zambia

April 2024

Sidonie East

Multilateral Carbon Tax Treaty (MCTT)

April 2024

Tatiana Falcão

Working Paper

A Climate Treaty for the Global Taxation of Carbon

April 2024

Tatiana Falcão

Research in Brief

Are Trade Rules Undermining Taxation of the Digital Economy in Africa?

March 2024

Karishma Banga, Alexander Beyleveld

Working Paper

Are Trade Rules Undermining Taxation of the Digital Economy in Africa?

February 2024

Karishma Banga, Alexander Beyleveld

Research in Brief

Tax Treaty Shopping and Developing Countries: Serious Potential for Tax Revenue Losses

November 2023

Maarten van ’t Riet, Arjan Lejour

Working Paper

Is Transparency Enough? An Examination of the Effect of the Extractive Industry Transparency Initiative (EITI) on Accountability, Corruption and Trust in Zambia

October 2023

Sidonie East

Working Paper

Tax Treaty Shopping and Developing Countries

September 2023

Maarten van ’t Riet, Arjan Lejour

Working Paper

Inclusive and Effective International Tax Cooperation: Views From the Global South

August 2023

Lucinda Cadzow, Martin Hearson, Frederik Heitmüller, Katharina Kuhn, Okanga Okanga, Tovony Randriamanalina

Working Paper

Tax Treaty Norms Among Lower- Income Countries and the Role of the UN Model: Past, Present and Potential

August 2023

Martin Hearson, Frederik Heitmüller, Vincent Arel-Bundock

Journal Article

Unsuccessful Implementation of the OECD Transfer Pricing Guidelines in Low Income Countries: The Case of Ethiopia

July 2023

Nathanael Tilahun, Abebe Gebrehiwot Yihdego

Research in Brief

Diffusion of OECD Transfer Pricing Regulations in Eastern Africa: Agency and Compliance in Governing Profit-Shifting Behaviour

May 2023

Cassandra Vet

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…

6 September 2024

ICTD policy impact featured in Institute of Development Studies’ latest Annual Review

Among IDS’ successes highlighted in its Annual Review 2023-24 was the pioneering research by ICTD that led to a change…

15 May 2024

Negotiations for new UN Framework Convention on Tax – what next?

Martin Hearson

The UN ad hoc committee concluded yesterday the first round of negotiations for the final parameters – or the “terms…

28 November 2023

Can the UK’s new international development strategy support fairer and more effective taxation systems?

Wilson Prichard, Martin Hearson, Max Gallien

Last week, the UK government published a new White Paper on International Development which sets out its approach to international…

9 August 2023

Global tax governance: Understanding the past, charting the future

This week, the UN released the advance version of the Secretary General’s report on the “Promotion of inclusive and effective…

4 April 2023

African revenue authority researchers gather to share insights on driving evidence-based tax policy

The ICTD hosted a four-day workshop which brought together a group of partners from the research departments of the tax…

16 March 2023

Call for Consultants: International Tax Project in Lower-Income Countries

The International Centre for Tax and Development is seeking six consultants for a cross-country comparative research project. The project will…

Taxation & Transparency Short Course

8 August 2017 – 00:00

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Institute of Development Studies, Falmer, United Kingdom

The ICTD is pleased to annouce a new four-day course on Taxation and Transparency to be held at the Institute of Development Studies from August 8-11th. https://youtu.be/L4N4p7agD8U The Topic: There is now very substantial and growing interest in tax transparency

Two-day Conference – ‘Lifting the Veil of Secrecy: Tax Havens, Capital Flows and Developing Countries’

21 November 2016 – 00:00

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Norwegian School of Economics, Helleveien, Bergen, Norway

What is the role of the tax avoidance industry? How can the challenges that tax havens represent be mitigated? On 21 and 22 November 2016, leading academics, practitioners and investigative journalists from all over the world meet in Bergen,