PhD Programme
The Institute of Tax Law has a vibrant postgraduate research programme. The Institute considers PhD students to be a central part of our research programme and essential to training the next generation of tax scholars.
Students pursuing a research degree at the Institute benefit from a vibrant academic community and have the opportunity to attend regular seminars and events. All students have access to the Queen Mary University of London Law Library and major electronic databases, as well as the library of the Institute of Advanced Legal Studies, University of London.
We currently have two PhD students on full scholarships: Jones Bahfri Abanda and Deus Mugabe.
Jones Bahfri Abanda
Jone’s thesis is on tax policy and tax compliance in Cameroon. His research analyses the evolution of tax policy and compliance in Cameroon, from colonial rule to the present. It demonstrates how coercive tax reforms entrenched distrust and resistance among indigenous populations, shaping post independence reforms that, despite modernization efforts, remained constrained by administrative complexity, weak institutional capacity, and inequitable burdens. Key tax reforms such as UDEAC’s harmonization initiatives in the 1970s, structural adjustment reforms of the 1980s and 1990s, and the consolidation of a modern tax code in the early 2000s are examined as attempts to align tax compliance with international development thresholds.
The study questions contemporary challenges including informality, corruption, perceptions of inequity, and low compliance ratios, which persist despite successive reforms. Employing a critical narrative methodology, it situates tax policy within broader governance dynamics, emphasizing the importance of transparency, fairness, and citizen participation in fostering compliance. It argues that the present tax policy/compliance framework reflects the interplay of colonial legacies, global tax governance, and digitalisation trends. Yet the absence of sociological inclusiveness in reform design perpetuates friction between taxpayers and the state. This tension, manifest in low compliance rates and high informality, underscores the need for reforms grounded in trust, accountability, and contextual responsiveness.
Deus Mugabe
Deus’ thesis is on transfer pricing in Africa. Following the Base Erosion and Profit Shifting Project of 2013- 2015, most of sub - Saharan African countries enacted transfer pricing rules. All of these countries adopted the arm’s length principle (ALP) – based transfer pricing regime. The ALP – based transfer pricing regime commands that associated enterprises should be treated as separate legal entities for the purpose of ascertaining the appropriate prices of intra-group transfers of goods and services.
In implementing the ALP, majority of the sub - Saharan African countries rely on the OECD Guidelines on transfer pricing. For poor developing countries, the OECD Guidelines are too complex and cumbersome to administer. Tax administrations in Sub-Saharan Africa face several challenges in implementing the ALP – based transfer pricing regime. Some of the challenges faced by tax administrations include capacity challenges, resource constraints, lack of comparables, among others. The aim of this study, therefore, is to establish whether the ALP – based transfer pricing regime is viable and fit for purpose in the sub-Saharan Africa.
Past PhD research projects include the following:
- Whose Tax is it Anyway? Value Creation, Intangibles, and the Right to Tax the Income of Multinational Enterprises.
- The Implications of Cloud Computing and the Digitalisation of the Economy for the International Corporate Income Tax System.
- The Future of Tax Competition in an Era of Tax Transparency.
- Tax Coordination of Life Assurance Investment-Linked Policies in the European Union.
- International Corporate Taxation of MNEs in the Middle East and North Africa: The Challenges of Modernisation and Integration.
- Interaction of EU State Aid Rules and Tax Law: Towards a Sustainable Tax Rulings Framework.
- A Materialist Political Economy of Corporate Tax.
- Cross-Border Group Loss Relief in the European Union.
- The Recognition of the Effect of Passive Association on Controlled Transactions for Transfer Pricing Purposes.
- BRICS and International Tax Law.
Individuals interested in pursuing a PhD at the Institute should contact the relevant academic to discuss their research proposal. Although we cannot guarantee that an offer will be made, discussion with an academic can help refine the research topic.