Concerns in Developing Countries about the OECD Inclusive Framework for BEPS. A Case Study of Uganda

Purpose: This paper deals with the concerns of developing countries over the implementation of the OECD Inclusive Framework on BEPS. It evaluates the ability for the Inclusive Framework in developing countries to deliver results as envisioned in developed countries. It follows a study conducted in Uganda as a case study for developing countries. 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 must unite and rally around agreed positions; collaborate with developed countries; increase participation in engagements where decisions are made; undertake building capacity of tax administrations in international tax rules, data mining and analysis; and introduce qualifying domestic minimum top-up tax (QDMTTs) and / or repeal of existing digital services taxes upon adoption of pillar two.