International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Global Tax 50 2017: Alexandra Readhead

Alexandra Readhead

Alexandra Readhead is a new entry this year

Alexandra Readhead's work focuses on issues of tax avoidance and other forms of illicit financial flows by multinational extractive companies in developing countries. Readhead has directly assisted governments in Sierra Leone, Guinea, Ghana, Tanzania, Zambia, and Cote d'Ivoire on strengthening legal frameworks against abusive transfer pricing in the mining sector. She is technical adviser to the Intergovernmental Forum on Mining, Metals and Sustainable Development (IGF) on its programme 'Tax Base Erosion and Profit Shifting in the Mining Sector in Developing Countries'.

The IGF BEPS in mining programme is a two-year collaboration with the OECD Centre for Tax Policy and Administration to equip the tax authorities of resource-rich developing countries with policy guidance and practical tools to confront aggressive tax planning by mining multinationals.

In 2017, Readhead also published the Toolkit for Transfer Pricing Risk Assessment in the African Mining Industry. The toolkit is the result of collaboration between GIZ and the African Tax Administration Forum (ATAF) aimed at helping tax authorities identify and detect transfer pricing risks in the mining sector. The government of Cote d'Ivoire is already using the toolkit in tax audits in the mining sector.

Over the coming year, she will build on the achievements of 2017 and continue to coach tax authorities on transfer pricing in Guinea, Sierra Leone, Liberia, South Africa, Tanzania, Senegal and Zambia, and publish new research on comparing anti-avoidance measures in oil and gas, and mining.

International Tax Review: Where are the challenges for tax administrations attempting to broaden their tax base and balancing these efforts with accommodating private sector needs?

Alexandra Readhead: Developing countries desperately need investment to contribute jobs and revenue. But, to attract this investment, they may need to offer tax incentives to compensate for a lack of infrastructure, administrative capacity and stable government. While these trade-offs may be necessary, the challenge is to make the right one. In Cote d'Ivoire, research by OpenOil into the Yaoure gold mine has shown the investor's internal rate of return was already very high compared to other gold mines, in which case the five-year tax holiday was probably unnecessary. Meanwhile the holiday cost government $120 million in tax revenue. Navigating the trade-offs involved in attracting investment is complicated.

Part of the work I am doing with the IGF is to inform these compromises in resource-rich developing countries by helping governments get a better sense of the potential cost of tax incentives, including the ways investors may use incentives to maximise the tax benefit beyond what was anticipated by government. Investors should also consider the political sustainability of the demands they place on governments. Recent events in Tanzania have shown that overly generous tax incentives may come back to bite investors.

ITR: Do you think institutional efforts to close loopholes for tax avoidance have taken on a quicker pace this year? Are goalposts moving fast enough or too fast?

AR: There continues to be a huge amount of activity at the international level and among developing countries to close loopholes for tax avoidance. Between 1995 and 2014, the number of African countries with transfer pricing rules has grown by 600%, according to EY. They are developing standalone transfer pricing regulations, building specific expertise, setting up specialised transfer pricing units and working together to share best practices through ATAF.

However, there remains a question as to whether the goalposts are the right ones, and whose interests they favour. This is clear from the recent OECD BEPS deliberations, which were limited to developed countries, which are now binding developing countries to the new international tax standards through the inclusive framework. Some aspects of the new standards are helpful to developing countries, for example, country-by-country reporting. However, given they are particularly exposed to multinational tax avoidance due to their disproportionate reliance on corporate income tax as a major source of tax revenue, and have limited financial and human resource to implement complex rules, there is a strong argument for simpler legal and institutional 'goalposts' that developing countries can inform and enforce. In mining this might include using index prices to calculate sales revenue for income tax, or setting limits on deductions for common cost categories. Neither measure is arm's length, but might be justifiable given the administrative challenges facing developing countries. The goalposts are moving quickly, the question is whether they will get developing countries where they need to go.

The Global Tax 50 2017

View the full list and introduction

The top 10 • Ranked in order of influence

1. US Tax Reform Big 6

2. Dawn of the robots

3. The breakdown of global consensus

4. The fifth estate

5. Margrethe Vestager

6. Arun Jaitley

7. Sri Mulyani Indrawati

8. Pascal Saint-Amans and Achim Pross

9. Richard Murphy

10. Cristiano Ronaldo and Lionel Messi

The remaining 40 • In alphabetic order

Tomas Balco

Piet Battiau

Monica Bhatia


Rasmus Corlin Christensen

Seamus Coffey

Jeremy Corbyn

Rufino de la Rosa

Fabio De Masi

The Estonian presidency of the Council of the European Union

Maria Teresa Fabregas Fernandez

The fat tax

Maya Forstater

Babatunde Fowler

The GE/PwC outsourcing deal

The Gulf Cooperation Council (GCC)

International Consortium of Investigative Journalists (ICIJ)

Meg Hillier

Chris Jordan

Wang Jun

James Karanja

Bruno Le Maire

John Pombe Joseph Magufuli

Cecilia Malmström

The Maltese presidency of the EU Council

Paige Marvel

Theresa May

Angela Merkel

Narendra Modi

Pierre Moscovici

The European Parliament Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA)

The Paris Agreement

Grace Perez-Navarro

Alexandra Readhead

Heather Self


Tax Justice Network

Donald Trump

United Nations Committee of Experts on International Cooperation in Tax Matters

WU Global Tax Policy Center

more across site & bottom lb ros

More from across our site

The forum heard that VAT professionals are struggling under new pressures to validate transactions and catch fraud, responsibilities that they say should lie with governments.
The working paper suggested a new framework for boosting effective carbon rates and reducing the inconsistency of climate policy.
UAE firm Virtuzone launches ‘TaxGPT’, claiming it is the first AI-powered tax tool, while the Australian police faces claims of a conflict of interest over its PwC audit contract.
The US technology company is defending its past Irish tax arrangements at the CJEU in a final showdown that could have major political repercussions.
ITR’s Indirect Tax Forum heard that Italy’s VAT investigation into Meta has the potential to set new and expensive tax principles that would likely be adopted around the world
Police are now investigating the leak of confidential tax information by a former PwC partner at the request of the Australian government.
A VAT policy officer at the European Commission told the forum that the initial deadline set for EU convergence of domestic digital VAT reporting is likely to be extended.
The UK government shows little sign of cutting corporate tax, while a growing number of businesses report a decline in investment as a result of the higher tax burden.
Mariana Morais Teixeira of Morais Leitão overviews Portugal’s new tax incentive regime designed to boost the country’s capital-depleted private sector.
Septian Fachrizal, TP analyst at the Directorate General of Taxes, outlines how Indonesia is relying heavily on the successful implementation of pillar one.