World Tax Policy in the World Tax Polity? An Event History Analysis of OECD/G20 BEPS Inclusive Framework Membership

58 Pages Posted: 16 Sep 2021 Last revised: 22 Apr 2022

See all articles by Shu-Yi Oei

Shu-Yi Oei

Duke University School of Law

Date Written: September 6, 2021


The last decade has seen the emergence of a new global tax order spearheaded by the OECD and G20 and characterized by increased multilateral consensus and cooperation. This new order appears to reflect the emergence of a new “world tax polity” with shared structures, practices, and norms, which have been shaped through the work of the OECD, G20, and other global actors. But what are the pathways by which this new world tax polity has emerged?

Using event history regression methods, this Article investigates this question by studying membership in the OECD/G20 BEPS Inclusive Framework, a multilateral tax agreement among 141 member countries that is a centerpiece of the new tax order. Sociological scholarship regarding world polity emergence posits that membership in this Inclusive Framework could have been driven by normative, coercive, or mimetic processes. Of these possibilities, this Article finds that Inclusive Framework membership seems to have proliferated through a combination of normative and coercion-based pathways. Specifically, acculturation through prior involvement in certain OECD tax initiatives and inclusion in contemporaneous European Union tax haven listing processes (a form of naming and shaming) were associated with a significantly higher hazard of membership. By contrast, imitation of other countries did not appear to be a significant pathway.

These findings highlight how international organizations and blocs have worked in concert to shape international tax policy and global tax consensus. More broadly, they show how world polity proliferation as a result of international organizations’ leadership can be amplified by parallel pressures and processes initiated by other powerful blocs. These findings carry important implications for the substantive content of global tax policy, where such policy is made, and its chances of success.

Keywords: taxation, OECD, international tax, global minimum tax, BEPS Inclusive Framework, tax avoidance, tax evasion, base erosion, profit shifting, tax policy, international relations, treaties, international law

JEL Classification: F53, H20, H25, H26, H27, H29

Suggested Citation

Oei, Shu-Yi, World Tax Policy in the World Tax Polity? An Event History Analysis of OECD/G20 BEPS Inclusive Framework Membership (September 6, 2021). Yale Journal of International Law, Vol. 47, 2021-22, Boston College Law School Legal Studies Research Paper No. 568, Available at SSRN:

Shu-Yi Oei (Contact Author)

Duke University School of Law ( email )

Box 90360
Durham, NC 27708-0360
United States

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