Concerns of Developing Nations Regarding the OECD Inclusive Framework on BEPS: A Case Study of Uganda

Purpose: This paper addresses the concerns of developing countries regarding the implementation of the OECD Inclusive Framework on BEPS. It also assesses the success factors for the Inclusive Framework in these countries. The study, conducted in Uganda as a case study, revealed that while the Inclusive Framework is generally appreciated in developing nations, it is paramount to evaluate the potential advantages of the Inclusive Framework for their individual jurisdictions before adoption. Materials and Methods: Interview of the selected tax experts was used as a method of delivery because it provided the study with a deeper understanding of the subject matter .The in-depth one-on-one online interviews with the five tax experts using an unstructured interview guide and Microsoft Teams allowed for free flow and deep discussion of the subject matter Findings: The study found out that although the inclusive framework is well received in developing countries, its benefits are not yet clear. As such, countries must evaluate the likely benefits of the inclusive framework and compare with their Digital Services Taxes before adoption. Unique Contribution to Theory, Practice and Policy: The study recommends that developing countries unite and advocate for common positions, collaborate with developed countries, enhance participation in decision-making processes, build the capacity of tax administrations in international tax rules, data mining, and analysis, and consider introducing qualifying domestic minimum top-up taxes (QDMTTs) and/or repealing existing digital services taxes upon adopting Pillar Two.