A Different Unified Approach to Global Tax Policy: Addressing the Challenges of Underdevelopment

Experts from the North have long tried to teach countries in the South how to tax. For decades, they assumed that the main challenges were domestic and that there was a right answer to be found somewhere in the developed world, and then replicated everywhere else. Only more recently have they turned to the international realm, yet their solutions remain tied to technical rules designed by a few specialists, as exemplified by the OECD Secretariat’s “Unified Approach”. This Article argues that such technocratic approaches are set to fail developing countries, for as long as they continue to overlook the background substantive and procedural causes of underdevelopment at both the national and international levels. These involve difficulties in applying complex rule sets due to various location-specific factors, as well as the very way in which global tax policy is developed, who influences the process, and the resulting distributive consequences.