At the Table, Off the Menu? Assessing the Participation of Lower-income Countries in Global Tax Negotiations

Rasmus Corlin Christensen, Martin Hearson, Tovony Randriamanalina

Research output: Working paperResearch

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Since 2013, the formal structure of global corporate tax policymaking at the OECD has changed. Decisions are no longer made by 37 OECD members, but by 137 countries from all regions and levels of development through the ‘Inclusive Framework’ (IF). Official documentation emphasises that all countries participate on an ‘equal footing’, but some participants and observers have emphasised that developing countries in particular face practical obstacles that lead to unequal participation in practice. In this paper, we assess these claims, drawing primarily on 48 interviews with negotiators, policymakers and stakeholders involved in global tax discussions. We find that the explosion in formal membership has not in itself led to the step-change in developing country influence that the raw numbers imply. This is because of a combination of structural obstacles that are not unique to the IF, and some challenging aspects of the OECD’s way of working. Yet, lowerincome countries have made some modest achievements to date, and there are signs of incremental progress towards a more effective presence. We develop a typology of mechanisms through which successes have been achieved: association with the efforts of more powerful states, anticipation of lower-income countries’ needs by the OECD secretariat and others, collaboration to form more powerful coalitions, and the emergence of expert negotiators with individual authority.
Original languageEnglish
Place of PublicationBrighton
PublisherInternational Centre for Tax and Development
Number of pages35
ISBN (Print)9781781187326
Publication statusPublished - Dec 2020
SeriesICTD Working Paper


  • International taxation
  • Multinational enterprises
  • OECD
  • Inclusive framework
  • Negotiations

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