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Talk by Daisy Mugadza: “The process of the new OECD/G20-Inclusive Framework international order — a friend or a foe to the developing world?”
July 24, 2025 @ 11:00 am – 12:00 pm
Talk by Daisy Mugadza (PhD candidate in Law, CISRUL)
In recent times the international tax regime has been impacted by the related issues of Base Erosion and Profit Shifting as well as the digitalisation of the economy. In the general context of such problems, even largely in response thereto, emerged the OECD/G20-Inclusive Framework on BEPS, an inclusive forum in which all members participate on an “equal footing” in the standard setting, monitoring and implementation of the BEPS Project and its Actions. Also emerging in this overall context, the Two Pillar Solution as the Framework’s agreed resolution to the digitalisation challenges. The introduction of both these aspects, however, has not been without controversy including, inter alia, critiques of the forum as just another manifestation of entrenched elitism within international tax law. Accordingly, the core question of this paper concerns to what extent the Inclusive Framework’s process can be viewed as inadequate in addressing the concerns and interests of developing countries. Through the use of library/desktop-based research, the paper critically engages with aspects including the history of institutions and inclusive fora in global taxation as well as arguments which have been levied both in favour of and against the Framework’s process from the perspective of the developing world, to answer this core question. It concludes that due to issues which can be broadly captured under the headings of legitimacy (and inclusivity) as well as justice, the process of the new OECD-Inclusive Framework cannot be viewed as being or having been a ‘friend’ to the developing world. Rather it is a ‘foe’ and perhaps solution sits with moving negotiations to the United Nations but also, in the interim, defining the parameters of inclusion in line with instrumentalist accounts of legitimacy. This may be further accompanied by systematic research into how it is that developing countries conceptualise ideas such as inclusivity, fairness and justice.
