From Rule Takers to Emerging Architects: Uganda, the East African Community, and Structural Constraints in Global Tax Governance

Abstract

This study analyzes Uganda and the East African Community’s (EAC) positioning within the evolving architecture of global tax governance, specifically focusing on the Base Erosion and Profit Shifting (BEPS) and Two-Pillar solutions. This research utilizes a structural power theoretical lens and a qualitative exploratory case study design to examine how institutional asymmetries and technical capacity constraints influence the bargaining power of developing nations. Data were collected through key informant interviews with tax policymakers and analysis of policy documents. The findings reveal that, despite formal inclusion in the OECD Inclusive Framework, Uganda and the EAC remain “rule-takers” due to dominant expert networks and complex administrative demands of new standards like Pillar Two. The study concludes that without significant investment in domestic technical capacity and enhanced regional coordination, fiscal sovereignty will remain elusive. It is recommended that Uganda prioritize South-South cooperation through ATAF and advocate for simplified tax rules suitable for low-capacity administrations.