PhD Thesis

"Cross-Border Allocation of Income Taxing Rights to Low-Income Countries"

Summary

The purpose of my PhD thesis is to investigate taxing rights of low-income countries with respect to non-resident corporations' income. It asks two primary questions. First, how is income derived by non-resident corporations taxed under domestic laws of low-income countries? Second, to what extent are these domestic taxing rights restricted by bilateral income tax treaties concluded with G20 member states? It investigates twenty-four low-income countries and their bilateral income tax treaties with G20 member states.

The structure of my PhD thesis is based fundamentally on two classifications. The first is a classification of income into three categories. The investigation of each category forms one of the three substantive chapters of my thesis. The second is a classification of low-income countries into "income tax law families" based on the origins and structures of their income tax laws. This forms a basis for a comparative analysis. Whilst the first classification settles the overall structure of the thesis, the second sets out a foundation for the internal structure of each chapter. Each of these two classifications is briefly presented below in visual form.