Global Economic and Development Policies

SCTI Annual Report 2023

2023 ANNUAL REPORT ON THE ACTIVITIES CARRIED OUT BY THE SOUTH CENTRE TAX INITIATIVE

The South Centre’s interventions have had a significant impact in helping developing countries bring about major reforms to the international tax system in 2023. Key achievements include the passage of the historic resolution in the United Nations General Assembly for the initiation of a UN Framework Convention on International Tax Cooperation, the successful end of a twenty year long negotiation in the UN Tax Committee for taxing computer software, the passage of an enhanced version of the Subject to Tax Rule in the UN Tax Committee for ending non-taxation in tax treaties, country level revenue estimates on the OECD digital tax solution vs Digital Services Taxes for the 85 combined Member States of the South Centre and the African Union, and extensive in-country capacity building for several South Centre Member States for taxing the digital economy and tax treaty negotiations.

(more…)

South Centre Statement to G-24, 16 April 2024

STATEMENT BY DR. CARLOS CORREA, EXECUTIVE DIRECTOR OF THE SOUTH CENTRE, TO THE MINISTERS AND GOVERNORS MEETING OF THE INTERGOVERNMENTAL GROUP OF TWENTY-FOUR (G-24)

16 April 2024, Washington D.C.

At the G-24 Ministers and Governors meeting, South Centre highlighted the many economic challenges facing developing countries and called for the urgent reform of the international  financial architecture.

(more…)

Dialogue with the G77+China Countries, 11 April 2024

A Dialogue with the G77+China Countries

Summit of the Future: risk and opportunities for developing countries

Co-organised by South Centre & Transnational Institute

11 April 2024, 13:00-15:00 (CET)

Geneva, Switzerland

Venue: International Environment House II, Chemin de Balexert 7-9, 1219 Vernier

(more…)

SC Statement to ECOSOC Special Meeting – Net Wealth Taxes, 18 March 2024

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.

(more…)

SC Statement to ECOSOC Special Meeting – Tax Cooperation at UN, 18 March 2024

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…

(more…)

South Centre Inputs – UN Tax Convention, 15 March 2024

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.

(more…)

Tax Cooperation Policy Brief No. 37, 29 January 2024

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.

(more…)

SC, IsDB, UNCTAD Side Event, 20 January 2024

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

(more…)

SC Statement at HRC on HRs & 2030 Agenda, 18 January 2024

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

(more…)

Research Paper 189, 21 December 2023

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.

(more…)