Building Resilience for Health Emergencies, Pandemics and One Health
Co-Branded Event hosted by the South Centre at the 2nd G-20 Health Working Group Meeting
6:30 – 8:00 pm, 9 April 2024
Brasilia, Brazil
THE ROLE OF NET WEALTH TAXES IN PROMOTING EQUALITY AND FINANCING THE SDGS
South Centre Statement to ECOSOC Special Meeting on International Cooperation in Tax Matters
18th March 2024
The South Centre, an intergovernmental think tank of developing countries with 55 Member States from Asia, Africa and Latin America and the Caribbean, is pleased to share its views on the role of net wealth taxes in promoting equality and financing the SDGs.
PROMOTING INCLUSIVE AND EFFECTIVE TAX COOPERATION AT THE UN
South Centre Statement to ECOSOC Special Meeting on International Cooperation in Tax Matters
18th March 2024
The South Centre, an intergovernmental think tank of developing countries with 55 Member States from Asia, Africa and Latin America, congratulates the Chair and Members of the Bureau on their appointment to the all-important ad hoc committee to elaborate the Terms of Reference (ToR) for a UN Framework Convention on International Tax Cooperation (“UN Tax Convention”). The Ad Hoc Committee has a genuinely historic mandate as it has to design the architecture of the long-standing demand of the developing world for a UN Tax Body…
South Centre Inputs on “Terms of Reference for a UN Framework Convention on International Tax Cooperation”
15 March 2024
The South Centre provided its inputs to the work of the United Nations’ Ad Hoc Committee to draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation. The Chair of the Ad Hoc Committee invited stakeholders to provide inputs to inform the work to be undertaken by the Committee.
The Terms of Reference are the foundation of the architecture of the Convention, which has the potential to fundamentally reform the international tax system to make it fairer for developing countries.
The Ad Hoc Committee was constituted consequent upon the historic resolution adopted by the General Assembly on 22nd December 2023. The United Nations Framework Convention aims to strengthen international tax cooperation and make it fully inclusive and more effective.
A Decade of the Indian Advance Pricing Agreement Programme: Achievements and Challenges
By Priyanka Mashelkar and Apoorv Tiwari
India’s Advance Pricing Agreement (APA) programme was introduced in 2012 with the objective of reducing transfer pricing disputes and providing certainty to taxpayers on their international transactions. In the last decade or so, the programme has proven to be a successful dispute mitigation and resolution mechanism. The authors use data and statistics from a recently released report by the Central Board of Direct Taxes (CBDT) in India to highlight the success of the programme, while also acknowledging the challenges ahead, especially as taxpayers’ expectations from the programme continue to rise.
Side Event to the 19th NAM Summit and the Third South Summit
“Leveraging the Potential of South-South and Triangular Cooperation for the Decade of Action”
Co-organized by the Islamic Development Bank, South Centre and UNCTAD
20 January 2024, 14:30 – 15:30
Kampala, Uganda
Venue: Victoria Ballroom, Speke Resort Munyonyo
Statement of the South Centre at the Sixth Intersessional Meeting of the Human Rights Council on Human Rights and the 2030 Agenda
18 January 2024
Leveraging human rights in the fight against illicit financial flows and corruption through greater international tax cooperation and fiscal transparency
Status of Permanent Establishments under GloBE Rules
By Kuldeep Sharma
The objective of this Research Paper is to comprehensively identify and analyse all Permanent Establishment (PE) related provisions under the global minimum tax of the Organisation for Economic Co-operation and Development (OECD), which is implemented through the Global Anti Base Erosion (GloBE) Model Rules. The analysis has led to the conclusion that PEs hold a significant position and facilitate application of GloBE Rules.
The GloBE Rules have introduced certain new facets involving application of PE provisions when there is no tax treaty; no Corporate Income Tax (CIT) in the source state, and have brought in the concept of stateless PEs. These newly-introduced facets have widened the scope of PEs to enable application of the GloBE Rules in specific situations which would otherwise have remained outside the ambit of taxation.
The paper concludes with an observation that the OECD’s Inclusive Framework is drafting the provisions of Amount A in a manner that results in consistency with GloBE Rules. Likewise, acceptance of “deemed PE” for GloBE rules should be extended to Amount A as well. By doing so, a tax nexus would be provided in source jurisdictions, which will allow profits attributable to Multinational Enterprises (MNEs) in a digitalized economy (without physical presence) getting taxed under domestic rules of these source (market) jurisdictions. This would have been a much simpler solution and would have eliminated the complexity of Amount A rules to a large extent, as we see today.
Panel During the United Nations Conference on Trade and Development (UNCTAD) e-Week
“Overcoming the fragmentation of digital governance: what role for the Global Digital Compact and e-trade rules?”
Co-organized by the South Centre (SC) and the University of St. Gallen
7 December 2023
Geneva, Switzerland
Opening Remarks by Dr. Carlos Correa, Executive Director of the South Centre, at the “Conference on South-South Cooperation in International Tax Matters: Don’t cede your taxing rights by signing a blank cheque”, co-organized with the Global Alliance for Tax Justice (27 November 2023)
The Conference is taking place at a time of severe challenges to the global economy and, particularly, for the achievement of the Sustainable Development Goals. Rising borrowing costs, tight global financial conditions and high debt burdens are constraining the fiscal space of many developing countries. These conditions make domestic resource mobilization through tax collection more important than ever. The taxation of foreign multinational corporations in the digital economy, in particular the Big Tech firms, has now become imperative both for providing much-needed revenues and for levelling the playing field of domestic companies in our countries.
Statement by the South Centre on the Historic UN Resolution Calling for a UN Framework Convention on International Tax Cooperation
23 November 2023
The South Centre strongly welcomes the adoption on 22 November 2023 of the historic resolution in the Second Committee of the UN General Assembly on the “Promotion of inclusive and effective international tax cooperation at the United Nations”. The resolution calls for establishing a “Member State-led, open-ended ad hoc intergovernmental committee for the purpose of drafting terms of reference for a United Nations framework convention on international tax cooperation” and is arguably the most significant development in international taxation in the modern era. The South Centre has been actively engaged in supporting these negotiations, in partnership with various institutions from the Global South and allies from the Global North, and commends the African Group in the UN in New York for their leadership of the developing world in steering through this momentous resolution.
Taxation of the Digital Economy
by Adnan Sose, Nicolás Tascon and Anders Viemose
As globalisation has pushed through complex inter-State trade in goods and services, in parallel there is a growing complexity in determining the taxation of Multinational Enterprises (MNEs) in an increasingly digitalized economy. This report reviews existing bilateral tax treaties between South Centre’s Member States and States where most digitalised MNEs are headquartered, using a threshold of EUR 750 million in annual turnover to limit the number of in-scope MNEs in the study. This analysis produced primary data on South Centre Member States’ source taxing rights scores and the implications of this on tax treaty negotiations to enable effective taxation in the digital economy through the inclusion of the United Nations (UN) solution for digital taxation, Article 12B of the UN Model Tax Convention. Further, the study sought to identify ‘weak’ tax treaties with low source taxing rights which merited a comprehensive renegotiation beyond the inclusion of Article 12B. Furthermore, the reports examined the treatment of “Computer Software” in the tax treaties under study, and concluded with recommendations going forward.
