International Taxation

SouthViews No. 223, 14 July 2021

Financial integrity for sustainable development: Importance of developing country joint action on tax, corruption and money-laundering 

By Dr. Ibrahim Mayaki

Countries are beginning to realize that the landmark agreement on the Sustainable Development Goals will be unrealized if financing is not found for the agenda. Much of that financing can be found if illicit financial flows are stopped. In March 2020, the Presidents of the United Nations General Assembly and Economic and Social Council convened a High-Level Panel on International Financial Accountability, Transparency and Integrity for Achieving the 2030 Agenda (FACTI Panel) to review global cooperation and recommend further actions by the international community as a contribution. Dr. Ibrahim Mayaki, the Co-Chair of the FACTI Panel, outlines the measures that the FACTI Panel recommended to combat tax abuse, corruption and money-laundering. He emphasizes the importance of developing countries taking a leading role in proposing solutions, and the value of inclusive international institutions. The text below is based on remarks that were made at a briefing to the Group of 77 and China in Geneva in April 2021, jointly organized by the FACTI Panel Secretariat and the South Centre. The Panel’s full report can be read at: http://www.factipanel.org/report.

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Statement, July 2021

Statement by the South Centre on the Two Pillar Solution to Address the Tax Challenges Arising From the Digitalisation of the Economy

The South Centre takes note of the statement by 130 members of the OECD/G20 Inclusive Framework (IF) on a two-pillar solution to address the tax challenges arising from the digitalisation of the economy. The agreement by the members is indeed historic and marks progress in the right direction. Unfortunately, the agreed upon solution is limited and disappointing as it falls short of the more ambitious and transformational reforms needed for a balanced agreement that fully responds to the concerns of developing countries, especially in the backdrop of the socioeconomic challenges posed by the COVID pandemic. Nine jurisdictions have not agreed with the statement, with the reasons still not public; however, it is a signal that cannot be ignored.

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Tax Cooperation Policy Brief 15, June 2021

Conceptualizing a UN Multilateral Instrument

By Radhakishan Rawal

Recent changes to the United Nations (UN) Model Tax Convention have resulted in provisions that are more advantageous for developing countries in raising revenue through international taxation, i.e. taxation of foreign income. These include taxation of income from automated digital services, software payments, capital gains and others. Normally, these would be incorporated into bilateral tax treaties through time-taking negotiations. A UN Multilateral Instrument (MLI) provides a speedy manner for updating multiple tax treaties through a single negotiation. This will help developing countries in collecting revenue more quickly. This Policy Brief discusses the possible structure of such an MLI.

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SouthViews No. 189, 17 January 2020

Enabling and Benefitting from Tax Avoidance: The Case of Canada in Africa’s Extractive Sector

By Alexander Ezenagu, PhD

The treatment of multinational entities as separate entities for tax purposes is incompatible with economic reality. As such, multinational entities are able to erode tax bases and shift profits to low tax jurisdictions. Due to the base erosion and profit shifting activities of multinational entities, African countries struggle to achieve the Sustainable Development Goals (SDGs) – to eradicate poverty, invest adequately in infrastructure and its industries, significantly reduce illicit financial flows and strengthen domestic resource mobilization – as they rely heavily on corporate taxation for a large part of their public revenue.

If African countries are to achieve their SDGs, there is an urgent need for a new international tax system that aligns where economic activities occur with where profits are taxed. A practical alternative is the unitary taxation of multinational entities. Unitary taxation treats multinational companies as a single entity, allocating the global profit to the jurisdictions where economic activities occur and value is created.

This article calls for the purposeful study of the unitary taxation approach to income allocation and serious consideration of its merits by the relevant supranational bodies. (more…)

SouthViews No. 166, 16 March 2018

Trump’s launch of a global trade war

By Martin Khor

Last week’s action by President Donald Trump has ended the United States’ leadership on liberal trade and may trigger a global trade war with major damaging consequences. On 8 March, Trump signed a proclamation to raise tariffs of steel by 25% and aluminium by 10%. It sent shockwaves across the world not only because of the losses to metal exporters, but due to what it could well signify: the start of a global trade war causing economic disruption in many countries, and that may also damage if not destroy the multilateral trade system. (more…)

SouthViews No. 144, 20 February 2017

The planned US border tax would most likely violate WTO rules

By Martin Khor

As the US Congress and President consider whether to introduce a border adjustment tax, a major question is whether such a measure will violate the rules of the World Trade Organization. Experts have good reason to believe the tax in several ways go counter to the WTO. But there are also shortcomings in the WTO system that could limit its usefulness in stopping the US if it is determined enough. A shorter version of this article was published by the IPS. This is the second of a two part series on the US border tax plan. (more…)

SouthViews No. 143, 17 February 2017

Beware of the new US protectionist plan, the border adjustment tax

By Martin Khor

A new protectionist device is being planned in the United States that could devastate the exports of developing countries and cause American and other foreign companies to relocate. The complexities and implications of the proposed border adjustment tax are explained in this article. A version of this article was published by IPS. A second article on this issue will be published soon. (more…)