Background
The International Institute for Sustainable Development (IISD) is an award-winning independent think tank working to accelerate solutions for a stable climate, sustainable resource management, and fair economies. Our work inspires better decisions and sparks meaningful action to help people and the planet thrive. We shine a light on what can be achieved when governments, businesses, non-profits, and communities come together. IISD’s staff of more than 300 experts come from across the globe and from many disciplines. With offices in Winnipeg, Geneva, Ottawa, and Toronto, our work affects lives in nearly 100 countries. .
Scope
As global tax rules grow more complex and cross-border disputes become more frequent, the need for fair, effective, and inclusive tax dispute resolution mechanisms has never been more urgent. Ongoing negotiations toward a United Nations Framework Convention on International Tax Cooperation, alongside new processes under the Organisation for Economic Co-operation and Development’s (OECD’s) Two-Pillar solution, present a timely opportunity to reassess the current landscape of international tax dispute resolution. In this context, IISD is launching a new research agenda to explore existing mechanisms for resolving international tax disputes, evaluate their limitations, and draw lessons from other international regimes, such as trade and investment law, that may offer relevant insights. This work aims to inform policy discussions and support the design of dispute resolution frameworks that respond to the needs and capacities of developing countries.
Objectives
Currently, the international tax dispute landscape consists of a patchwork of different dispute prevention and resolution procedures, ranging from mutual agreement procedures, advanced pricing agreements, mandatory bilateral arbitration, and there may be an inclination to explore other models from international economic law, such as investor–state dispute settlement (ISDS) in the absence of a fixed and universally accepted tax dispute resolution system.
The consultant will be tasked with developing a new, original research paper that provides a clear, policy-oriented analysis of international tax dispute resolution mechanisms. The paper should critically assess current approaches and their limitations while drawing on comparative insights from dispute resolution practices in investment, trade, and other international legal regimes.
This research will build on IISD’s previous work on the topic, which will feature in forthcoming publications, and is intended to contribute to a broader dialogue on reforming international tax dispute resolution frameworks. The final output will be a high-quality, peer-reviewed research paper that sets out concrete policy recommendations, with particular attention to the perspectives and priorities of developing countries.
Scope of Work
Under the guidance of the IISD Tax and Investment Teams, the consultant will:
1. Conduct a comprehensive literature review, including:
- Existing academic, policy, and institutional literature on tax, investment, and trade dispute resolution;
- Current and proposed mechanisms under the OECD, the United Nations, and other relevant bodies;
- Reforms under the United Nations Commission on International Trade Law Working Group III process (ISDS), World Trade Organization dispute panels, and regional instruments (e.g., African Continental Free Trade Area, United States–Mexico–Canada Agreement);
- Developments in the UN Framework Convention on International Tax Cooperation, including the Protocol on Dispute Resolution;
- The potential for a standing multilateral dispute resolution body for tax.
2. Undertake consultations with IISD teams, including:
- Virtual interviews with IISD’s trade and investment law experts to gather internal insights on dispute resolution design;
- Coordination with the tax team on implications for capacity-constrained jurisdictions.
3. Conduct research:
- Critically assess and compare the existing patchwork of dispute resolution frameworks, ranging from mutual agreement procedure, advanced pricing agreements, mandatory bilateral arbitration, and there may be an inclination to explore other models from international economic law, such as ISDS, and others, in the context of their effectiveness for tax disputes;
- Recommend an ideal model to resolve this dysfunctional patchwork of international tax dispute resolution solutions currently available;
Include and address comments by internal and external reviewers.
4. Support the launch and dissemination
Expected Deliverables
- Annotated outline and updated research plan
- Literature review
- Draft research paper, including
- Executive summary (two pages max);
- Revised full-length paper (8,000–10,000 words);
- Bibliography and reference list.
Qualifications
- Advanced degree in international tax law, public international law, or a related field
- Demonstrated extensive research experience
- Strong writing and analytical skills, with a track record of high-quality research outputs
- Experience working with or advising international organizations or governments preferred
Location
Remote. IISD will not be applying for residency and work permits for this position on behalf of the applicant.
Deadline of Application
Applications will be reviewed on a rolling basis until filled.
Timeline
Total consultancy period: 4 months (negotiable, July– October 2025 preferred)
Application Process
This is a consulting position. Submissions must be in English.
Candidates must hold appropriate work authorization for locations where they expect to be based.
Please include the following:
- A CV
- An expression of interest (one page)
- Writing sample (preferably related to tax, investment, or trade dispute resolution)
Only those candidates we wish to interview will be contacted.
