International Tax Cooperation

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…)

South Centre Annual Report 2023

South Centre Annual Report 2023

The South Centre carries out multiple activities to support developing countries with policy-oriented research, inputs and advice for negotiations and capacity building. See a summary of the South Centre’s activities in the Annual Report 2023.

(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 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…)

SC Statement – Conference on SSC in International Tax Matters, 27 November 2023

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.

(more…)

SC Statement – UN Resolution on UN Framework Convention on International Tax Cooperation, 23 November 2023

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.

(more…)

Tax Cooperation Policy Brief No. 36, 26 October 2023

Beyond the Two Pillar Proposals

A Simplified Approach for Taxing Multinationals

By Sol Picciotto, Muhammad Ashfaq Ahmed, Alex Cobham, Rasmi Ranjan Das, Emmanuel Eze, Bob Michel

This paper puts forward an alternative to the proposed multilateral convention under Pillar One of the BEPS project, by building on and going beyond the progress made so far. A new direction was signalled in 2019 by the G-24 paper proposing a taxable nexus based on significant economic presence, combined with fractional apportionment. The resulting measures agreed under the two Pillars entail acceptance in principle of this approach, and also provide detailed technical standards for its implementation. These include: (i) a taxable nexus based on a quantitative threshold of sales revenues; (ii) a methodology for defining the global consolidated profits of MNEs for tax purposes, and (iii) detailed technical standards for defining and quantifying the factors that reflect the real activities of MNEs in a jurisdiction (sales, assets and employees).

The time is now right to take up the roadmap outlined by the G-24. The work done shows that technical obstacles can be overcome, the challenge is essentially political. This paper aims to provide a blueprint for immediate measures that States can take, while engaging in deliberation at national, regional and international levels for a global drive towards practical and equitable reforms. Unitary taxation with formulary apportionment is the only fair and effective way to ensure taxation of MNEs where economic activities occur, as mandated by the G20. It can ensure that MNE profits are taxed once and only once, provide stability and certainty for business, and establish a basis for international tax rules fit for the 21st century.

* Also available in French, Spanish, Portuguese and Arabic.

(more…)

SC Statement to G-24, 10 October 2023

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)

10 October 2023, Marrakesh, Morocco

To address the global polycrisis, developing countries need to come together to demand reforms in the international rules & architecture for debt, development finance, trade & tax to achieve equitable outcomes, fight climate change and meet SDGs.

(more…)

Vacancy Announcement

Vacancy Announcement:

Research Consultant – International Taxation

Duty Station: Remote

The South Centre is seeking to fill a Researcher position in the South Centre Tax Initiative, the organization’s flagship project for promoting cooperation among developing countries on international tax matters. The Researcher will be required to carry out analysis to support the ongoing negotiations on international taxation in the United Nations and the OECD. The analysis will focus on the implications for developing countries of the various international tax standards under negotiation with a view to providing the South Centre’s Member States and developing countries from the G-77+China with policy advisory and capacity building. The Researcher will also be required to produce revenue estimates of the policy proposals of developing countries and where necessary, a comparison with the proposals of developed countries. The Researcher is expected to have deep knowledge of international taxation, particularly in transfer pricing and a strong background in economics and quantitative economic analysis.

(more…)

0

Your Cart