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The report examines national investment laws as versatile domestic policy instruments, tracing their evolution from 1950s development-driven codes to 1980-2010 models aligned with international treaty standards. It identifies seven primary functions of contemporary investment laws: governing admission, conferring incentives, facilitating investment, guaranteeing legal protection, managing disputes, specifying investor obligations, and monitoring oversight. The authors argue against 'off-the-shelf' models, suggesting instead a functional framework where design is tailored to national context and sustainable development objectives. The report warns against the risks of 'legal enclaves' and the potential for costly litigation when treaty-style protections and advance consent to international arbitration are incorporated into domestic law.

The document examines national investment laws as versatile policy instruments, tracing their shift from national development tools (1950-1979) to mechanisms for incorporating international treaty standards (1980-2010). It identifies seven primary functions of contemporary investment laws: regulating admission, administering incentives, facilitating investment, providing legal protection, managing disputes, specifying investor obligations, and supervising investments. The report argues against a 'one-size-fits-all' model, suggesting instead that laws be designed based on a country's specific policy objectives and regulatory capacity. It provides a detailed framework for policymakers to evaluate existing laws and design new ones, emphasizing the need to reduce legal risks associated with investor-state dispute settlement (ISDS) and inefficient tax incentives.

The report examines national investment laws as versatile policy tools, tracing their evolution from 1950s development-focused laws to the 1980-2010 trend of aligning national legislation with international investment treaties. It identifies seven primary functions of contemporary investment laws: governing admission, managing incentives, facilitating investment, providing legal protection, managing disputes, specifying investor obligations, and supervising investments. The document argues against a 'one-size-fits-all' model, instead offering a framework for policymakers to align the functions and content of their laws with specific national objectives and sustainable development goals, while warning against the legal and financial risks of incorporating treaty-style protections and prior consent to international arbitration.

The report examines how national investment laws have evolved from domestic development tools in the 1950s to instruments reflecting international treaty standards between 1980 and 2010, and finally toward a modern era of diverse, context-specific designs. Based on a survey of 70 laws, it identifies seven primary functions of investment laws: governing admission, administering incentives, facilitating investment, guaranteeing legal protection, managing disputes, specifying investor obligations, and monitoring investment. The authors argue against 'off-the-shelf' models, instead proposing a framework where policy-makers first define their ultimate objectives—such as promoting sustainable development—and then determine which specific functions and legal structures are appropriate for their national context.

RMI analysis finds that utility-scale solar and onshore wind are already cheaper to build than new natural gas plants in Texas, even without the Chapter 313 tax incentives. The report argues that excluding renewables from the next iteration of Chapter 313 via House Bill (HB) 5 is economically inefficient, as it would require $150 to $300 in taxpayer funds per kilowatt to make natural gas competitive. Furthermore, rapid adoption of clean technologies could allow Texas to retain $130 billion in-state through federal tax credits, with approximately 35 percent of that amount stimulating the electricity sector.

The document explains the mechanics of the GloBE rules, which aim to ensure a 15% minimum effective tax rate (ETR) for large multinational enterprises (MNEs) with consolidated revenues of €750 million or more. It outlines three primary policy responses for developing countries: implementing a Qualified Domestic Minimum Top-up Tax (QDMT) or a general national minimum tax, revising existing tax incentives that lower the ETR, or focusing on other priorities if the impact is minimal. The guide also provides a step-by-step methodology for countries to assess their exposure using country-by-country (CBC) reports and analyzes legal obstacles, such as fiscal stabilization clauses in investment contracts and Bilateral Investment Treaties (BITs), that may hinder tax reforms.

The document explains the mechanics of the GloBE rules, which aim to ensure large multinational enterprises (MNEs) pay a minimum effective tax rate of 15%. It outlines three primary response options for developing countries: introducing a locally collected minimum tax (either a Qualified Domestic Minimum Top-up Tax or a general national minimum tax), reviewing and reforming tax incentives that lower the effective tax rate below 15%, or focusing on other priorities if the impact is negligible. The guide also provides a step-by-step methodology for assessing a country's exposure based on available data and analyzes legal obstacles, such as fiscal stabilization clauses in investment contracts and Bilateral Investment Treaties (BITs), that may hinder tax reforms.

The document explains the OECD/G20 Pillar Two GloBE rules, which aim for a 15% global minimum tax on multinational enterprises (MNEs) with revenues over EUR 750 million. It details how top-up taxes are collected via the Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR), and how countries can pre-empt these by adopting a Qualified Domestic Minimum Top-Up Tax (QDMT). The guide analyzes the impact of GloBE on various tax incentives, providing a framework for countries to assess their exposure using country-by-country (CBC) reporting. It also addresses legal barriers to tax reform, specifically fiscal stabilization clauses in investment contracts and protections under Bilateral Investment Treaties (BITs), such as the Fair and Equitable Treatment (FET) standard.

The document argues that employee savings in France, totaling 158 billion euros, are often invested in climate-harmful activities without the knowledge of savers. It proposes 14 specific measures to remedy this, including a mandatory 'tricolore' indicator for controversial activities, the requirement for ISIN codes for FCPE funds, and fiscal incentives for responsible savings plans. It also suggests restricting asset managers' access to the employee savings market unless they adhere to strict climate policies, particularly regarding the phase-out of fossil fuel investments.

The document examines the OECD's two-pillar solution for digital taxation, noting that while the EU and most African Inclusive Framework (IF) members support it, significant gaps remain. African entities like the ATAF and G24 advocate for the redistribution of total profits rather than residual profits, higher minimum taxes, and non-binding dispute resolution. The author highlights that 'stabilization clauses' in investment treaties may prevent African countries from adjusting tax incentives to meet minimum tax rules without losing revenue to home states. The paper suggests the EU could support Africa through technical assistance and by advocating for transparent, regionalized arbitration centres.

The report explores the 'Use of Research Evidence' (URE) by policymakers in Africa, focusing on the intersection of CSO research and tax policy. Through case studies in Tunisia, Nigeria, Zambia, and Uganda, it finds that while the technical quality of CSO research is generally high, its influence is primarily determined by non-technical factors such as the timing of engagement, the perceived non-partisan reputation of the CSO, and existing relationships with policymakers. The document provides strategic lessons for CSOs to increase their policy impact and recommendations for funders to better support internal capacity and flexible funding timelines.

The policy brief examines the conflict between the OECD's Pillar Two Global Minimum Tax and 'fiscal stabilization' clauses, which are common in developing economies and can lock in tax incentives for decades. It argues that these clauses risk exposing governments to international arbitration if they raise taxes to meet the 15% minimum. The author recommends that OECD model legislation explicitly state that the global minimum tax applies regardless of stabilized incentives and that Inclusive Framework members agree that good-faith adjustments to align with GloBE rules do not constitute breaches of international law or investment treaties.

The policy brief examines the conflict between the OECD's 'Second Pillar' global minimum tax of 15% and existing fiscal stabilization clauses in national laws and investment contracts, particularly in developing nations. It argues that these clauses may hinder governments from updating tax policies without risking international litigation. The authors propose that the OECD's model legislation should explicitly state that the global minimum tax applies regardless of stabilization agreements and that good-faith adjustments to align with GloBE rules should not be considered breaches of international law or investment treaties.

The policy brief examines the conflict between the OECD's Pillar Two global minimum tax and 'fiscal stabilization' clauses often found in the national laws and investment agreements of developing countries. These clauses can freeze tax incentives and prevent states from raising effective tax rates to 15% without risking international arbitration. The authors recommend that the OECD's model legislation explicitly state that the global minimum tax applies regardless of stabilization agreements and that members of the Inclusive Framework agree that good-faith adjustments to align with GloBE rules are not violations of international law or investment treaties.

The document examines the G7 proposal for taxing the digitalised economy, specifically the OECD's Pillar 1 and Pillar 2. It argues that the US-led amendments—including a 15% global minimum effective tax rate and high revenue thresholds for Pillar 1—disadvantage African nations. The brief highlights that many MNEs operate in Africa without a physical presence, exploiting loopholes to avoid tax. It warns that the proposed rules may force African countries to surrender unilateral taxing rights (like Digital Service Taxes) without gaining significant revenue, as most MNEs in Africa fall below the G7's high thresholds. The authors advocate for a UN-led global tax body to ensure greater legitimacy and equity.

The report analyzes the impact of three US federal tax subsidies—the expensing of intangible drilling costs (IDC), percentage depletion, and accelerated amortization of geological and geophysical (G&G) expenses—on the profitability of oil and gas projects from 1998 to 2019. Using a financial model of 2,450 fields, the authors find that these subsidies increased the expected net present value of projects by billions of dollars annually, often exceeding $20 billion in high-price years. The benefits were heavily concentrated in unconventional shale developments in regions such as the Permian Basin and Appalachia, and disproportionately benefited independent firms over integrated ones. While subsidies provided 'super normal' profits during high-price periods (2007-2014) without significantly altering drilling decisions, they were critical for the viability of marginal projects during price drops, such as in 2016 for oil and 2010-2012 for gas in Appalachia.

The report analyzes the Zona Franca de Manaus (ZFM), noting that while it is named a 'free trade zone', it functions more like an 'enterprise zone' by focusing on regional development and local employment rather than international trade. The authors argue that current tax incentives have not significantly improved productivity or wages, with 59% of employees earning up to two minimum wages in 2019. The document recommends redefining the ZFM's identity and linking tax benefits to local hiring quotas, education, infrastructure reinvestment, and sustainable activities that leverage the Amazon biome's comparative advantages.

The report argues that the OECD's Pillar Two (GloBE) proposal, which uses accounting profits to determine the Effective Tax Rate (ETR), fails to account for timing differences common in the mining sector, such as accelerated depreciation. This discrepancy could lead to 'top-up taxes' being paid to parent company jurisdictions rather than host countries, potentially reducing investment in developing nations. The document evaluates three policy solutions: loss carryforwards and income inclusion credits, deferred-tax accounting, and the use of local tax rules, while also addressing the challenges of permanent differences like tax holidays and stabilization clauses in mining contracts.

The document argues that the OECD's Pillar Two (GloBE) proposal, while intending to reduce tax evasion, may inadvertently penalize resource-rich developing countries due to timing differences in how mining investments are depreciated. Because mining requires massive upfront capital, local tax laws often allow accelerated depreciation, leading to low effective tax rates (ETR) in early years. Under current GloBE rules, this could trigger 'top-up taxes' payable to the parent company's home country rather than the host country, potentially reducing investment and transferring billions in tax revenue from developing to developed nations. The report evaluates three solutions: a combination of loss carry-forwards and credits, deferred tax accounting, and the use of local tax rules for ETR calculations, while also noting the challenge of permanent differences caused by tax holidays and stabilization clauses.

The document analyzes the risks posed by the OECD's Pillar Two (GloBE) rules to the mining sector, specifically regarding 'timing differences' between accounting profits and taxable income. It argues that without proper resolution, these differences—often caused by accelerated depreciation—could lead to double taxation and the transfer of tax revenues from developing nations to the home countries of multinational corporations. The report evaluates three potential solutions: loss carry-forwards/tax credits, deferred tax accounting, and the use of local tax rules.