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The Treaties Explorer: New Data for Better Negotiation

December 1, 2021



Globe of world with lines showing data on tax treaties

The Tax Treaties Explorer: New Data for Better Negotiation


    The use of tax treaties by developing countries is controversial, to say the least. Best case scenario? Tax treaties help to attract foreign direct investment by reducing the risk of double taxation. Evidence for this is weak. Worst case scenario? They become a vehicle for multinational tax avoidance leading to huge revenue losses for developing countries.

    Despite the uncertain benefits and widely recognized risks, developing countries continue to sign tax treaties. In such cases, an understanding of good treaty practice – how countries in a similar position have negotiated, reviewed, or modified their treaties to better protect their tax base – can help lay the foundations for fairer and more sustainable tax treaties.

    This event, jointly hosted by the Global Tax Program (GTP)  and International Center for Tax and Development (ICTD), will introduce the Tax Treaties Explorer, and demonstrate how it can be used by practitioners and researchers.

    The new Tax Treaties Explorer website provides a means to compare and contrast different treaties in ways that complement analysis of the legal wording.  It is based on a new dataset of almost every tax treaty signed by developing economies. For non-specialist policymakers and others with a stake in tax policy, this is an accessible entry point to understand treaties in comparative context.


    • An overview of the ICTD’s Tax Treaty Explorer.
    • Presentations of three research projects that use the Tax Treaty Explorer’s data:

      Tax Treaties and Foreign Direct Investment Flows: A Replication Study by Martin Hearson, Marco Carreras, and Anna Custers

     Tax Treaty Aggressiveness: Who is Undermining Taxing Rights in Africa? by Markus Meinzer, Maimouna Diakité, Lucas Millán    Narotzky, and Mirsolav Palansky

     Taxing Profits from International Maritime Shipping in Africa: Past, Present and Future of UN Model Article 8 (Alternative B) by Tatiana Falcão and Bob Michel



  • Time (approx.)


    9:00 – 9:05 AM

    Welcome and Opening Remarks from the World Bank: Ana Cebreiro, Senior Economist, Fiscal Policy and Sustainable Growth Unit, MTI, WBG (5 min)


    9:05 – 9:30 AM

    Presentation by Martin Hearson, Research Fellow (ICTD)

    “Introduction to the ICTD Tax Treaty Explorer” (25 minutes)



    Presentation by Ashima Neb (WB – Platform for the Collaboration on Tax) on the PCT Tax Treaty Negotiation Toolkit (10 minutes)


    9:40 – 10:30 AM

    Research presentations (15 minutes each, with 5 minutes of `slack’)


    Presentation 1:

    “Tax Treaty Aggressiveness: Who is Undermining Taxing Rights in Africa?” by Lucas Millán Narotzky


    Presentation 2:

    “Past, present and future of article 8 (alternative B) of the UN Model” by Tatiana Falcão


    Presentation 3:

    “Tax treaties and foreign direct investment flows: a replication study” by Martin Hearson


    10.30 – 10:55 AM

    Q&A– Ana Cebriero

    10:55 – 11:00 AM

    Concluding Remarks & Key Takeaways by the Chair (5 min)



    Ms. Ana Cebreiro, Senior Economist, World Bank.  Ana Cebreiro is a Senior Economist in the Global Tax Team anchored at the Fiscal Policy and Sustainable Growth Unit of the Macroeconomies, Trade and Investment Global Practice at the World Bank. Currently Ana is leading the international tax work at the World Bank (WB), including the tax transparency agenda, at the global level. Since she joined the WB in 2013, she has been implementing technical assistance tax projects and supporting lending operations covering both tax policy and administration. She has more than 25 years of expertise in the tax area. Before joining the WB, she worked for 9 years in the OECD (Paris), at the Centre for Tax Policy and Administration. Previously, she held positions as an economic consultant in DotEcon Economic Consulting and a research economist for the HM Revenue and Customs (HRMC) in the United Kingdom. Ana is from Spain and holds a PhD and MA in Economics from the University of Essex in the United Kingdom, and an MA in Applied Public Economics for the Universidad Autonoma de Barcelona.

    Dr. Martin Hearson, Research Fellow, International Center for Tax and Development (ICTD). Martin Hearson is a Research Fellow at the Institute of Development Studies, where he is International Tax Program Lead for the International Centre for Tax and Development (ICTD). His research focuses on the politics of international business taxation, and in particular the relationship between developed and developing countries. Before joining ICTD, Martin was a fellow in international political economy at the London School of Economics and Political Science, and before that he spent a decade working in the charity sector. He is the author of “Imposing Standards: The North-South Dimension to Global Tax Politics,” published by Cornell University Press.

    Ashima Neb, DRM Specialist, Platform for Collaboration on Tax (PCT), World Bank. Ashima Neb is a Domestic Resource Mobilization Specialist with the Platform for the Collaboration on Tax (PCT) Secretariat. She was formerly the Additional Commissioner of Income Tax at the Indian Revenue Service, where she has over twenty years of experience.

    Lucas Millán-Narotzky, Lawyer and Senior Researcher, Tax Justice Network. Lucas Millán-Narotzky is a lawyer and senior researcher in financial secrecy and corporate taxation at the Tax Justice Network. He has completed Bachelor’s degrees at Pierre et Marie Curie and Panthéon-Assas universities, followed by Master’s degrees at Paris-Sorbonne and Boston universities, specialising in international taxation.

    Dr. Tatiana Falcao, Policy Expert Consultant, World Bank & African Tax Administration Forum. Dr. Tatiana Falcao is a policy expert in international tax and environmental taxation, providing expert consultancy services to the World Bank and ATAF. She is the Coordinator for Helsinki Principle 3 (carbon pricing), at the Coalition of Finance Ministers for Climate Action. Tatiana was previously with the UN Environment Program and UN DESA, overseeing the work of the Committee of Experts in International Cooperation in Tax Matters.

    Ms. Marine Khurtsidze is the Head of Tax and Customs Policy Department at the Ministry of Finance of Georgia since 2021. She oversees formation of tax and customs policy, including international tax policy of Georgia. Ms. Khurtsidze is an Elected Chair of the Conference of the Parties to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) at OECD.  She has been supervising of the implementation of four minimum standards of Base Erosion and Profit Shifting Project (OECD) in Georgia and has been playing the role of the country representative at OECD to the following groups: WP 1 and ad-hoc group on the development of Multinational Instrument, Forum of Harmful Tax Practice and at the Bureau of this Forum, FTA MAP Forum and Steering Group of this Forum, Joint WP 6 – WP 10 Group on Country-by-Country Reporting and WP 2 on Tax Policy Analysis and Tax Statistics.


  • Event Recording on YouTube:


    PowerPoint Presentations and event blog can be accessed here:

Event Details