Taxing Multinationals: Three Lenses on International Tax Cooperation (Comments on UN Resolution 77/244, Promotion of Inclusive and Effective International Tax Governance at the United Nations)

Abstract

UN Resolution 77/244, adopted by the General Assembly on 30 December 2022, reaffirms earlier commitments by the United Nations to improve international tax cooperation, fight illicit financial flows, and combat aggressive tax avoidance and evasion. The resolution asks that the Secretary-General prepare a report on ways to “strengthen the inclusiveness and effectiveness of international tax cooperation.” The Secretary-General’s report is to analyze the current international tax framework, evaluate options, and outline potential next steps. As part of that process, the Secretary-General is to consult widely with Member States and other relevant actors including civil society. I welcome the opportunity as an academic and member of civil society to provide comments as part of this process. I have been writing for many years about taxing multinationals (including a book with this title (Eden, 1998)), and would like to share some comments that explore different ways to frame the issue of international tax cooperation. I hope that my comments may provide some useful guidance to UN policymakers as to the best path forward and potential pitfalls along the way in extending previous efforts at international tax cooperation. My comments start with a brief history of international tax cooperation. I then review and analyze three streams of research that may inform UN policymaking: the literatures on wicked problems, prescriptive public finance, and international regimes and global governance. I conclude with some suggestions for the way forward.

Keywords: international taxation, tax cooperation, tax competition, wicked problems, international regimes, international tax regime, double tax treaties, transfer pricing, tax avoidance, tax evasion, global tax governance, evidence-based policymaking, Pillar One, Pillar Two, complexity

JEL Classification: F23, H25, H26, K34, K420, K330, L11