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

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

April 2023

Cassandra Vet

Working Paper

Strategic Investment Tax Incentives in Africa: The Case of Tax Holidays in Uganda

April 2023

Ronald Waiswa, Solomon Rukundo

Journal Article

BEPS, Pillar 2, and the Replacement of Tax-Based Incentives With Nontax Incentives

April 2023

Michael Durst

Working Paper

Asymmetric Double Tax Treaties and FDI in Developing Countries: The Role of the Relief Method and Tax Sparing

March 2023

Pranvera Shehaj, Martin Zagler

Working Paper

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

August 2022

Abebe Gebrehiwot Yihdego, Nathanael Tilahun

Journal Article

It’s Time to Reform Transfer Pricing Benchmarking

June 2022

Michael Durst

Journal Article

Developing influence: the power of ‘the rest’ in global tax governance

May 2022

Martin Hearson, Rasmus Corlin Christensen, Tovony Randriamanalina

Journal Article

Grounding ActionAid’s Tax Justice Campaigns in Nigeria

April 2022

Mª Josep Cascant-Sempere (Kas)

Journal Article

The Rise of China and Contestation in Global Tax Governance

January 2022

Martin Hearson, Rasmus Corlin Christensen

Journal Article

The Politics of Taxing Multinational Firms in a Digital Age

January 2022

Martin Hearson, Margarita Gelepithis

Research in Brief

Taxing Profits From International Transport In Africa: Past, Present and Future of Article 8 (Alternative B) of the UN Model

December 2021

Bob Michel, Tatiana Falcão

Working Paper

Tax Treaties and Enterprise Outcomes: Evidence Across Developing African Countries

December 2021

Uchenna Efobi, Oluwabunmi O. Adejumo

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…

1 December 2021

ICTD’s ‘Taxing Africa’ book authors featured on ‘Between the Lines’ podcast

In this episode of Between the Lines, Jalia Kangave interviews Mick Moore, and Wilson Prichard who along with Odd-Helge Fjeldstad…

13 July 2021

Call for research proposals: Tax treaties and lower-income countries

Th International Centre for Tax and Development (ICTD) seeks proposals for research projects on tax treaties and lower-income countries, with…

14 January 2021

Understanding how lower-income countries participate in global tax negotiations

Since 2013, the formal structure of global corporate tax policymaking at the OECD has changed. Decisions are no longer made…

27 November 2020

ICTD’s Martin Hearson presents at Platform for Collaboration on Tax webinar

On November 4th, the Platform for Collaboration on Tax (PCT) hosted a public consultation webinar for the draft PCT Toolkit…

1 April 2020

ICTD analyses global corporate tax negotiations

Since the start of 2019, global discussions on corporate tax reform have proceeded under the auspices of the OECD and…

11 November 2019

Tax Notes Talk Podcast: Digitalisation and Developing Countries

David Stewart interviewed ICTD Research Fellow Martin Hearson for the Tax Notes Talk Podcast. The two discussed how the OECD’s…

Panel: Future of International Tax Governance

Virtual

5 June 2025 – 15:00

•

Timezone: Europe/London

The Institute for Austrian and International Tax Law and the Global Tax Policy Centre at the Vienna University of Economics and Business (WU Vienna) are hosting a panel discussion on the “Future of International Tax Governance”, in the context of

ICTD-IISD workshop: Negotiating Protocols of the UN Tax Convention

In person

4 February 2025 – 18:00

•

Timezone: America/New_York

Millennium Hilton New York One UN Plaza, New York, NY, USA

This workshop is aimed at tax experts and non-tax practitioners engaging in the negotiations of the protocols of the United Nations Framework Convention on International Tax. Join ICTD and the International Institute for Sustainable Development (IISD) for an in-person only

Seminar: Making Global Tax Governance Fit for the 21st Century

Virtual

16 October 2024 – 17:00

•

Timezone: Europe/London

The London School of Economic and Political Science (LSE) will be hosting a seminar on ‘Making global tax governance fit for the 21st century’, which will feature ICTD Research Director Martin Hearson who will present a paper of the same

ICTD at 10th EPRN Annual Economic Research Conference on boosting economic resilience to economic shocks

Virtual

27 June 2024 – 14:00

•

Timezone: Africa/Kigali

We are delighted to contribute to the 10th Annual Conference of the Economic Policy Research Network, Rwanda, which this year has been organised around the theme Boosting Economic Resilience to Economic Shocks. ICTD Research Director, Giulia Mascagni, has given welcome