Historical and Contemporary North-South Dynamics in International Tax Governance

In December 2023, the United Nations (UN) General Assembly adopted a landmark resolution launching intergovernmental negotiations toward a new Framework Convention on International Tax Cooperation. The resolution, initiated by Nigeria on behalf of the Group of African states and adopted with broad support from the Global South, brings the UN into an international governance arena where the high-income country dominated Organisation for Economic Cooperation and Development (OECD) until recently enjoyed unrivalled authority. International tax governance addresses the challenges that arise as states want to tax multinational enterprises (MNEs) in a coordinated way that avoids both double-taxation and under-taxation. The division of taxing rights over MNEs represents a distributive conflict that has historically been decided in favour of high-income countries. In order to place the current institutional dynamic in their proper historical context this thesis asks: To what extent have...Show moreIn December 2023, the United Nations (UN) General Assembly adopted a landmark resolution launching intergovernmental negotiations toward a new Framework Convention on International Tax Cooperation. The resolution, initiated by Nigeria on behalf of the Group of African states and adopted with broad support from the Global South, brings the UN into an international governance arena where the high-income country dominated Organisation for Economic Cooperation and Development (OECD) until recently enjoyed unrivalled authority. International tax governance addresses the challenges that arise as states want to tax multinational enterprises (MNEs) in a coordinated way that avoids both double-taxation and under-taxation. The division of taxing rights over MNEs represents a distributive conflict that has historically been decided in favour of high-income countries. In order to place the current institutional dynamic in their proper historical context this thesis asks: To what extent have Global South actors historically been able to influence institutional dynamics within the international tax regime complex and under what conditions have contemporary forms of Global South contestation emerged? Regime complex theory allows us to conceptualize the dynamics between multiple intergovernmental organizations (IGOs) that occupy a single governance space and the ways in which state actors shape and behave strategically within this structure. This thesis will show that Global South actors have historically been largely excluded from meaningful participation in global tax governance institutions and as a result international tax governance has been characterised by a remarkable continuity of regressive governance principles. Due to inherent deficiencies in the existing structure and structural changes in the global economy however, the existing structure is no longer satisfactory even to its former beneficiaries. Now that the old settlement has been disturbed, the OECD risks losing its legacy focal position within the regime complex as it struggles to gather consensus around the shape of reforms. This has created the incentive and opportunity for Global South actors to seek an alternative forum for inclusive reforms.Show less

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Historical and Contemporary North-South Dynamics in International Tax Governance