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

Chapter 4: The OECD’s BEPS Project and Lower-Income Countries

July 2018

Michael Durst

Book

Chapter 3: The Historical Evolution of Base Erosion and Profit Shifting

June 2018

Michael Durst

Book

Taxing Africa: Coercion, Reform and Development

May 2018

Mick Moore, Wilson Prichard, Odd-Helge Fjeldstad

Policy Brief

Linking Beneficial Ownership Transparency to Improved Tax Revenue Collection in Developing Countries

May 2018

Wilson Prichard

Book

Chapter 2: Poverty, Tax Competition, and Base Erosion

March 2018

Michael Durst

Book

Chapter 1: Taxing Multinational Business in Low-Income Countries

February 2018

Michael Durst

Working Paper

Assisting Developing Countries in Taxation after the OECD’s BEPS Reports: A Suggested Approach for the Donor Community

November 2017

Michael Durst

Working Paper

How Can Governments of Low-Income Countries Collect More Tax Revenue?

November 2017

Mick Moore, Wilson Prichard

Working Paper

How Kenya has Implemented and Adjusted to the Changes in International Transfer Pricing Regulations: 1920-2016

November 2017

Attiya Waris

Partner Publication

Lifting the Veil of Secrecy – Perspectives on International Taxation and Capital Flight from Africa

October 2017

Odd-Helge Fjeldstad, Sigrid Klæboe Jacobsen, Peter Henriksen Ringstad, Honest Prosper Ngowi

Policy Brief

What Have We Learned About International Taxation and Economic Substance?

June 2017

Sol Picciotto

Partner Publication

Global distribution of revenue loss from tax avoidance – Re-estimation and country results

March 2017

Alex Cobham, Petr Janský

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…

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…

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).