IGF 2023 WS #443 Taxing Tech Titans: Policy Options for the Global South

Wednesday, 11th October, 2023 (04:30 UTC) - Wednesday, 11th October, 2023 (06:00 UTC)
WS 4 – Room B-1

Global Digital Governance & Cooperation
Governing Digital Economy

Organizer 1: Gayani Hurulle, LIRNEasia
Organizer 2: Helani Galpaya, 🔒
Organizer 3: Abdul Muheet Chowdhary, South Centre

Speaker 1: Gayani Hurulle, Civil Society, Asia-Pacific Group
Speaker 2: Abdul Muheet Chowdhary, Intergovernmental Organization, Intergovernmental Organization
Speaker 3: Victoria Hyde, Technical Community, Asia-Pacific Group
Speaker 4: Alison Gillwald, Civil Society, African Group
Speaker 5: Mathew Olusanya Gbonjubola, Government, African Group


Helani Galpaya, Civil Society, Asia-Pacific Group

Online Moderator

Helani Galpaya, Civil Society, Asia-Pacific Group


Helani Galpaya, Civil Society, Asia-Pacific Group


Debate - 90 Min

Policy Question(s)

(i) What are the different digital taxation policy options available to countries in the Global South? (ii) How successful have tax regimes that have already implemented solutions been? Is this a viable policy option as more and more countries implement their own solutions? (iii) Is the OECD model most suitable to all countries, including the Global South? (iv) What are the challenges in scoping out and implementing digital taxation, particularly in the Global South?

What will participants gain from attending this session? The participants will gain an understanding of (i) the various policy options available to countries in the Global South, including revenue potential from the different options, with a particular focus on whether their countries should sign the Amount A multilateral convention by end 2023 (ii) which policy options have been favoured by various countries and stakeholder groups (iii) incentives for different countries and stakeholder groups to align with different policy options (iv) implementation challenges. These in turn could help participants understand the considerations for what policy option may work best in their countries/contexts.


The digital economy has been growing in recent years. Large technology multinationals operate in and derive profits from the Global South. However, tax systems in many countries are not designed nor equipped to obtain tax revenue from these technology multinationals. Select countries such as India, Colombia, and Nigeria have unilaterally implemented their own systems. But there are concerns about the lack of cohesiveness in approach. The OECD and UN have proposed their own treaty-based solutions. However, concerns have been raised on the revenue generating potential of some multilateral proposals, as well as the timelines for implementation. The proposal is for a 90-minute debate. This focuses on whether countries in the Global South should align with OECD solution, with a specific focus on whether countries should sign up for the OECD’s Amount A Multilateral Convention – on which countries are expected to take on stance by end 2023. The speakers represent a variety of stakeholder groups (including intergovernmental organizations, technology multinationals, governments, and civil society), bringing diversity in perspectiveFurther, the speaker list is diverse from a gender, age and regional lens.

 Session breakdown: 1. Introduction to session, pre debate Menti poll to get audience perspectives (10 minutes) 2. Framing the debate (5 minutes) 3. Opening statements by speakers (6 minutes each) (25 minutes) 4. Window for speakers, moderator to comment on statements made by other speakers/ask questions from one another (10 minutes) 5. Questions/comments from audience (15 minutes) 6. One-minute summaries  7. Post-debate Menti poll to understand audience perspectives (5 minutes) 8. Summary of session, session close (10 minutes)

The speakers may not raise questions during others’ opening remarks but can engage with points made by previous speakers during their own opening remarks. The 10-minute window after the opening remarks can be used for speakers' right to reply.

Expected Outcomes

Outputs: The session organizers will draw up a policy note, drawing on points made by speakers and participants. This will be published online and shared on social media channels. Outcomes: This session is expected to help participants understand which policy option may work best in their countries/contexts. We expect this to be a basis for nuanced discussion on the topic amongst policy practitioners, and wider engagement with relevant stakeholders.

Hybrid Format: The session will have both onsite and online speakers. Online participants will be allowed to contribute by speaking and/or inputting comments and questions via the chat channel. The moderator will monitor this channel. The moderator will read out questions raised via chat aloud to allow onsite participants to follow the discussion. A platform such as Slido, which allows both online and offsite participants to type in their questions, will be used to equalize opportunities for engagement. The two polls to understand the participants’ viewpoints before and after the debate will be conducted via the platform..

Key Takeaways (* deadline 2 hours after session)

- Digital taxation is a nascent yet dynamic space, whose impacts on social/digital justice and competition should be evaluated, alongside its revenue potential.

- The fate of the OECD Amount A proposal is uncertain, as power lies in the hands of a few (if not a single) countries. While the Global South may benefit, they will be price takers — therefore, domestic measures such as digital service taxes shouldn’t be ruled out.

Call to Action (* deadline 2 hours after session)

- Countries should consider revenue potential, impact on competition, and implementation costs and capacity when choosing between signing the OECD Amount A multilateral convention and imposing domestic taxation measures by end 2023.

- Digital tax must become a more prominent part of platform governance discourse. Multi-sectoral (finance, digital, competition, IR) dialogues are key to understanding various nuances.

Session Report (* deadline 26 October) - click on the ? symbol for instructions

This session explored on if/how countries in the Global South should tax large technology multinationals. A pre-session poll indicated that 81% of the audience believed that countries should be exploring policy options to impose taxes on large technology multinationals; 6% believed countries should not, while 13% were undecided.

Given the variety of policy options available, the workshop (organized in the style of a debate) looked to answer one specific, pertinent key question – should countries in the Global South sign onto the Amount A Multilateral Convention put forward by the The Organisation for Economic Co-operation and Development (OECD) and G20 by the end of 2023?

Helani Galpaya (CEO, LIRNEasia), moderated the debate. Five speakers. representing a variety of stakeholder groups and brought a multitude of viewpoints to the table. Gayani Hurulle (Senior Research Manager, LIRNEasia) framed the debate on the need to find mechanisms to tax large digital platforms given the growing centrality of these platforms in the economy.  Abdul Muheet Chowdary (Senior Programme Officer, South Centre) highlighted the revenue implications for countries. Victoria Hyde (Policy and Communications Manager, Asia Internet Coalition) drew on the experiences of the technology MNEs highlighting the benefits of having a uniform, multilateral system.  Mathew Olusanya Gbonjubola (Coordinating Director, Federal Inland Revenue Service of Nigeria and Co-Chair, UN Tax Committee) highlighted the viewpoints of a government that had made some bold decisions on the topic in the past. Meanwhile Alison Gillwald (Executive Director, Research ICT Africa) spoke on the equity and fairness elements of the proposals, also on the experiences of low capacity governments.

There were two key elements that became crucial to addressing the debate topic – first, whether countries in the Global South should sign onto this Amount A multilateral convention at any point in time; second, whether they should sign it -- and thereby forgo the option to implement domestic measures (if not already in place) – for another year.

The speakers were of mixed opinions. Some argued that the certainty of the OECD proposal, and the lower transaction costs for platforms, made signing the Amount A Convention a compelling one. This would allow low-capacity countries to obtain some revenue as opposed to none. However, some other speakers argued that the Amount A multilateral convention would only come into effect if at least 30 jurisdictions accounting for at least 60% of the Ultimate Parent Entities (UPEs) of in scope MNEs signed the convention. Given that many of the countries in the Global South were not UPEs of such MNEs, them signing onto the agreement would have little bearing on whether it moved forward or not – much rested in the hands of a few countries, such as the United States. The audience too was of mixed opinions, the post-session poll indicated. 39% were of the view that countries in the Global South should sign up for the Convention by the end of the year while 50% said they shouldn’t’. 11% were undecided.

The question-and-answer session highlighted that there was room for further capacity building on topics around digital taxation. Notably, an audience member from the Ministry of Finance from a Global South country indicated that this session was useful for his capacity building and requested technical assistance for aid his country’s policymaking on digital taxation. Overall, the debate highlighted that there were no clear-cut answers to topics around digital taxation particularly as this will be an ever important and dynamic topic, further increasing the need for engagement and debate on the topic.