Description
This paper examines how regional collaboration among Sub-Saharan African (SSA) tax authorities is reshaping North–South power relations in global tax governance. Over the past decade, most SSA countries adopted OECD-based transfer pricing (TP) rules to curb illicit financial flows and strengthened their capacity for TP audits. While these standards provide a framework to challenge profit-shifting, they also embed asymmetrical governance structures that privilege OECD norm-setters, multinational corporations, and professional service firms. The widespread adoption of OECD TP standards has created powerful network effects that discourage policymakers from pursuing simpler or more context-appropriate approaches (Vet, 2023), reinforcing institutional path dependency and governance lock-in. Yet, regional initiatives such as the African Tax Administration Forum (ATAF) are fostering new forms of Southern norm entrepreneurship. Through these platforms, African tax officials leverage shared expertise and technocratic collaboration to articulate regional priorities and challenge OECD dominance using socio-technical resources (Hearson, Christensen & Randriamanalina, 2022). In Finnemore and Sikkink’s (1998) terms, this development signifies a phase of norm emergence where SSA countries move beyond the role of passive norm-takers. It also shows that constructivist policy learning (Stone, 2004) is not just a process of socialization but also a vehicle for contestation and agency, demonstrating how regional cooperation can create new types of influence within seemingly locked-in global governance structures.
