Interesting news from Uganda, where the government announced in its latest budget that it has finished formulating its new tax treaty policy, and will be renegotiating treaties that don't comply. Seatini and ActionAid Uganda will no doubt chalk this up as a success! The news report linked to above also states that the the government plans to amend the awkwardly-worded anti-treaty-shopping clause in its Income Tax Act… [ 402 more words. ]

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Last week I re-read Jason Sharman’s classic Havens in a Storm, described by Tax Analysts’ Martin Sullivan as “one of the best books out there for tax experts trying to make sense of big countries' policies toward tax havens” (Sullivan’s review includes a length summary of the book). I was looking for a hook for this blog and, well, it was provided by… [ 1617 more words. ]

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Some charts based on the new tax treaties dataset.

Today the International Centre for Tax and Development (ICTD) and ActionAid are launching a new dataset that I’ve developed over the last year. It’s the product of over a year’s work, mostly by an intrepid team of research assistants in the LSE law department, to code the content of over 500 tax treaties signed by developing countries. ActionAid, who funded the research assistants’ time, have also used the dataset to construct a… [ 906 more words. ]

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In the recent Tax Justice Network Africa report on tax treaties, I had a go at estimating some costs to governments, based on a back-of-the-envelope figure for cross-border dividend and interests payments. This is similar to the methodology used by SOMO and the IMF. (It's a bit rough and ready, because some of the return on FDI figures I used will include reinvested profits, not cross-border remittances, but I've seen some other more sophisticated working recently that produces roughly similar figures.) [ 416 more words. ]

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The report I authored for Tax Justice Network-Africa is now available. It's based on field research done a year ago and has been a little while getting into print. Here's a link to read it online at academia.edu Here's a link to download the PDF And here's the introduction: There is growing attention on the question of tax treaties signed by developing countries. [ 702 more words. ]

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As my last post anticipated, the ratification of the UK-Senegal tax treaty was debated in parliament last week. It was great that a debate on the impact of a tax treaty between the UK and a developing country happened at all. Some important issues came up: What is the role of the Department for International Development in the UK's treaty policy with respect to developing countries? [ 1365 more words. ]

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Back in February, the UK and Senegal signed a bilateral tax treaty. The treaty is up for ratification this week, so I thought it time to take a look. Ratification happens through the delegated legislation committee, and entails very little debate. The last time a treaty between the UK and a developing country was ratified, I thought it was a shame that there had not been more discussion… [ 575 more words. ]

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Next month sees the results of the OECD's Base Erosion and Profit-Shifting project, as well as a discussion at the UN tax committee on alternative dispute resolution in tax treaties. India has apparently vetoed the inclusion of mandatory binding arbitration by default in the OECD model tax treaty, and it remains an optional provision within the UN model too. This post will show that arbitration provisions in treaties with developing countries are nonetheless on the march, and it will discuss some of the issues that this raises. [ 1129 more words. ]

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British tax treaties with developing countries, 1970-1981

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"We have some doubt whether it would really prove useful." The origins of UK opposition to a Global Tax Body.

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