UN tax convention
Right now, our governments are negotiating the biggest shakeup in history to global tax rules at the UN. The outcome of these talks – a world-first UN tax convention – will impact every one of us, wherever we are in the world, and shape people’s lives for generations to come.
It’s not just trillions of dollars on the line, but our democracies, human rights and planet.
The Tax Justice Network is working alongside campaigners, experts, policymakers and investors from around the world to help achieve the best outcomes for people, economies and planet.
What you’ll find on this page
Whether you’re just learning about the UN tax convention or are deeply involved in the negotiations, we’ve designed this page to get you the information you need.
Here’s what’s below:
⏱️60-second newcomer crash course New here? Start here. ↴
🔔Latest news The latest on the convention. ↴
💸Tax lost live counter We’re counting how much we tax missed out on since COP30 and the latest UN negotiations sessions started on 10 Nov 2025. ↴
🧩Build-a-Convention tracker What’s gone in and what still needs to go into the convention? See the latest negotiation updates. ↴
🛒“Who wants what?” database See what countries have said they want on specific policy issues under the convention. ↴
✊“Tax justice ABCs” in the convention The policies that make tax systems work for everyone equally, not just for the superrich. ↴
📢Social justice in the convention Securing a UN tax convention for gender rights, human rights, climate justice and education. ↴
⏱️60-sec crash course
👋New here? Start here 👉 What’s the UN tax convention?
🔔Latest news: UN Third Session and COP30 underway
12 Nov 2025 12:11pm GMT – Watch the civil society side event at the UN negotiations
In case you missed it, you can rewatch the civil society side event here to hear civil society views and proposals for the UN tax convention.
12 Nov 2025 11:51am GMT – “FfD Chronicle” newsletter resumes
The newsletter is published by members of the Civil Society Finance for Development Mechanism who are on the ground at the negotiations, offering invaluable and original insight. It’s only published during active negotiations. Follow it here.
Older updates
11 Nov 2025 2:45pm GMT – Intervention by Tax Justice Network’s Liz Nelson
Liz Nelson, Director of Advocacy and Research at the Tax Justice Network, made an intervention on the commitment to achieve a fair allocation of taxing rights. Her statement underscored the importance of ensuring that international tax rules work for all countries. Rewatch the intervention here (timestamp 57min) and read her full speech here.
11 Nov 2025 2:20pm GMT – Update on negotiations on taxing high-net-worth individuals
We’ve added an update summarising yesterday’s and today’s the negotiations on the commitment on effectively taxing high-net-worth individuals in specific. You can find this update in the Commitments area of the “Build-a-convention” section below.
10 Nov 2025 – 1:47pm GMT The first session of UN tax convention negotiations in Nairobi running from today into next week is now underway. Tune in live here. You can find streaming links for sessions scheduled for this week and next week at the bottom of this webpage.
💸Live tax counter
Tax missed out on since UN negotiations started on 10 NovApplying a small wealth tax on the superrich and making multinational corporations pay the dodged taxes they owe can cover the majority of countries’ climate finance costs, and leave most with billions in tax to spare towards public services. This would raise $2.6 trillion a year, our research shows.
We’re counting how much tax could have been collected since COP30 and the Third Session of UN tax convention negotiations started on Monday 10 November 2025 if these solutions were in place – solutions which the UN tax convention can best deliver.
Here are the six actions that experts and campaigners from around the world agreed in October 2025 for making the UN tax convention deliver on climate justice.
🧩Build-a-Convention tracker
Negotiating global conventions is messy work, so we’ve broken the process down into building blocks to help make it easier to follow.
Below you’ll find the “building blocks” – things like commitments and protocols – that need to go into the UN tax convention’s different sections. You can expand each building block to learn more about it and see the latest updates on its negotiations.
Countries already pre-agreed before the negotiations began on what building blocks should go into the convention and what these should look like. You can see these in the Terms of Reference. We’re working with campaigners around the world to help make sure countries stick to the world-changing terms they committed to.
Negotiating now
Protocols
The protocols of the convention are specific and important obligations that implement the convention’s objectives. Protocols allow these kind of obligations to be negotiated individually, making for an easier and faster negotiation process.
✒️ See the pre-agreed version of the Protocols▼
From the Terms of Reference adopted by the UN:
Protocols
14. Protocols are separate legally binding instruments, under the framework convention, to implement or elaborate the framework convention. Each party to the framework convention should have the option whether or not to become party to a protocol on any substantive tax issues, either at the time they become party to the framework convention or later.
15. Two early protocols should be developed simultaneously with the framework convention. One of the early protocols should address taxation of income derived from the provision of cross-border services in an increasingly digitalized and globalized economy.
16. The subject of the second early protocol should be decided at the organizational session of the intergovernmental negotiating committee and should be drawn from the following specific priority areas:
(a) Taxation of the digitalized economy
(b) Measures against tax-related illicit financial flows
(c) Prevention and resolution of tax disputes
(d) Addressing tax evasion and avoidance by high-net worth individuals and ensuring their effective taxation in relevant Member States
17. Protocols addressing the following topics, inter alia, could be considered:
(a) Tax cooperation on environmental challenges
(b) Exchange of information for tax purposes
(c) Mutual administrative assistance on tax matters
(d) Harmful tax practices
Currently negotiating (2)
🌍Cross-border services
Last updated: 3 Nov 2025
Explainer🧠
Taxing cross-border services is a key challenge in international tax negotiations. More and more services — from digital platforms to remote consulting — are now provided across borders without the provider ever setting foot in the customer’s country. Without clear and fair rules, this creates uncertainty over which country has the right to tax the income and raises the risk of double taxation or tax abuse. The Protocol offers an opportunity to agree inclusive and effective global rules for taxing different types of cross-border services, especially in an era of digitalisation and remote service provision.
Negotiation updates 🤝
15 Aug 2025: Second round of negotiations kicked off with scoping discussion on early protocol on cross-border services
Between Monday and Wednesday of the second round of negotiations, discussions on the early protocol for taxing cross-border services focused on the technical and political challenges of designing rules that are fair, feasible and adaptable across regions.
Delegations debated whether the protocol should be self-executing or require additional legal instruments. Some participants highlighted the need for clear and uniform withholding tax rates to provide certainty and limit opportunities for tax abuse, while others cautioned against rigid approaches that might reduce flexibility.
A major theme was the balance between simplicity and precision. Fixed, low withholding rates were seen by some as a way to ensure predictability and avoid double taxation. Others argued that service transactions vary too widely for a one-size-fits-all solution.
The debate also reflected North–South differences. Developing countries underlined the importance of predictable source-based taxation to protect their revenue base, while several developed countries emphasised administrative feasibility, alignment with existing OECD treaty practice, and safeguards against over-taxation.
Delegations also discussed the scope of covered taxes, which stemmed from differing characterisations of certain digital service taxes under national legislation. Questions were raised about whether the protocol could be ratified independently of the convention and how disputes arising from its application might be resolved.
Overall, the first three days revealed convergence on the urgency of establishing clearer global rules for cross-border services, but divergence on the appropriate design of withholding taxes and the legal framework required to implement them.
Previous updates (2)
21 July 2025 Member states’ written submissions on Workstream II co-leads’ draft issue note
Country submissions on the protocol for taxing cross-border services revealed sharp divisions between regions. Many developing countries, including the Africa Group, Brazil and others, rejected outdated physical presence rules and supported broader nexus definitions such as significant economic presence. They strongly favoured gross-basis withholding taxes as a simple and effective tool to secure source taxing rights, especially in contexts with limited administrative capacity. Many also saw these as a proxy for net taxation and a way to protect fiscal space.
By contrast, many developed countries emphasised physical presence, defended net taxation as economically efficient and consistent with OECD treaty practice, and cautioned that withholding could unfairly shift taxing rights towards source states.
Divergences also extended to the scope of services and the relationship with tax treaties. Global South countries pressed for broad coverage of digital and emerging services, as well as multilateral solutions to overcome restrictive treaties. Many Northern countries preferred a narrower scope aligned with existing OECD standards and defended the legitimacy of the bilateral treaty network.
27 June 2025 Draft issue note published by Workstream II co-lead (Chile)
A draft issue note has been published by the co-lead of Workstream II.
Key issues identified include differences among domestic laws on whether to tax services on a gross basis (withholding) regardless of where services are performed, or on a net basis linked to physical presence or permanent establishment.
The protocol will consider new nexus rules, such as significant economic presence and user participation, to ensure that source jurisdictions can exercise taxing rights even when services are provided remotely.
It will also define which types of services are in scope — for example, intra-group technical or managerial services, remote services and automated digital services — and which categories of taxes apply, including income and withholding taxes. Deliberations will address how to treat digital services taxes and whether to classify coverage by the name of a tax or by its nature.
Principles to guide the design are also under discussion: fairness, administrability, simplicity, neutrality and future-proofing, so that the rules remain relevant as business models evolve.
Analysis💡
Tax Justice Network’s analysis – 14 Oct 2025
From the Tax Justice Network’s perspective, negotiations on the protocol for taxing cross-border services made important headway by placing the need for predictable global rules for all types of services at the centre of the debate. However, they also revealed how far consensus remains.
Developing countries called for clear, low, gross-basis rates to protect source taxation and secure much-needed revenue. Many developed countries, by contrast, favoured net taxation and greater flexibility to maintain consistency with existing OECD treaty practice.
This divide reflects deeper structural imbalances in international tax rules — rules that have long deprived source countries of the ability to tax services and often failed to ensure that the countries where services are performed receive a fair share of tax revenue.
As the Tax Justice Network stressed in its submission, the protocol should not be limited to narrow fixes. It must lay the foundation for a multilateral system that replaces outdated nexus rules and complex transfer pricing with approaches that treat multinational companies as unitary entities and allocate profits according to real economic activity.
To make this possible, the protocol should retain a broad scope that captures all relevant services and introduce new nexus rules that move beyond the outdated requirement of physical presence. There is also a need to rebalance taxing rights towards source and market jurisdictions.
The ultimate test will be whether the protocol creates a future-proof system that prevents treaty shopping, secures taxing rights for the Global South, and supports domestic resource mobilisation for sustainable development.
❤️Dispute prevention and resolution
Last updated: 3 Nov 2025
Explainer🧠
Disputes over how much tax is owed and where it should be paid are common in cross-border bussiness, and when countries cannot resolve them efficiently, it creates uncertainty for governments and companies alike. This protocol represents a key opportunity to design universal mechanisms for preventing and resolving tax disputes in line with the principles set out in the Framework Convention.
By finding common ground on the rules for preventing and resolving tax disputes, the protocol can play a critical role in fulfilling the objectives of the Framework Convention, including the mobilisation of resources for sustainable development and the fulfilment of human rights
Negotiation updates 🤝
15 Aug 2025: Second round of negotiations closed with debates on the early protocol on disputes prevention and resolution
From Wednesday to Friday, negotiations on the early protocol for dispute prevention and resolution focused on scope, design, and balance between fairness and efficiency. Most countries agreed it should cover cross-border disputes, though some noted the overlap with domestic cases like transfer pricing. A key divide emerged over scope: Global North states favoured limiting the protocol to disputes under the UN framework, while Global South delegations pushed for broader coverage to address gaps in their limited treaty networks. On design, OECD members promoted strengthening the Mutual Agreement Procedure with mandatory binding arbitration, while many developing countries opposed this, citing sovereignty and capacity concerns, and instead advocated mediation, joint audits, and advance pricing agreements. There was general openness to opt-in/opt-out flexibility, though Southern countries warned that too much optionality could weaken effectiveness and pressed for minimum standards. Overall, the debates reflected persistent North–South divides: developed countries prioritizing certainty and arbitration, and developing countries stressing equity, access, and preventive mechanisms.
Previous updates (2)
21 July 2025 Member States make written submissions on Workstream III Co-Lead’s Draft Issue Note
Country submissions showed both common ground and sharp divergences. Most states agreed that the protocol should focus on cross-border disputes, with purely domestic cases left to national systems. There was broad recognition of the need to improve access for countries with limited treaty networks, particularly in the Global South, where capacity and information asymmetries exacerbate disputes. On scope, Global North states often preferred limiting mechanisms to disputes under the new UN framework, while some Southern states argued for broader coverage, including existing treaty and transfer pricing issues. A key fault line was arbitration: many OECD countries supported mandatory binding arbitration to strengthen the Mutual Agreement Procedure, while most developing countries opposed it, citing sovereignty, capacity constraints, and power imbalances, instead favouring mediation or preventive measures like joint audits, APAs, and risk assessment. On optionality, most countries accepted flexible opt-in/opt-out approaches, but Global South voices stressed the need for minimum standards to prevent fragmentation and ensure fairness.
27 June 2025 Draft issue note published by Workstream III Co-Leads (Jamaica and Germany)
The scope of the issues under the proposed Draft issue note is broad, covering both structural design choices and practical mechanisms for resolving tax disputes. Key debates include whether the protocol should apply only to cross-border disputes or also domestic ones; whether it should be limited to disputes under the UN Framework Convention and its protocols or provide broader access to dispute resolution for existing tax rules; and how to strengthen or reform the Mutual Agreement Procedure (MAP), including whether to introduce mandatory binding arbitration or mediation. It also addresses the role of investment and trade arbitration (ISDS) in tax disputes and whether the protocol should restrict forum shopping by multinational enterprises. Another central area is dispute prevention, with proposals for advance pricing agreements, joint audits, cooperative compliance, and better information exchange. Finally, the protocol must decide on the degree of optionality—whether countries can opt in or out of certain mechanisms, or whether minimum standards should be mandatory for all signatories
Analysis💡
Tax Justice Network’s analysis – 14 Oct 2025
From a Tax Justice Network perspective, the negotiations on the early protocol on dispute prevention and resolution revealed progress in acknowledging the failures of current mechanisms but also clear gaps that mirror the Tax Justice Network’s long-standing concerns. The broad agreement that the protocol should focus on cross-border cases both under the current rules like transfer pricing and new rules under the Convention is welcome. Global South delegations are right to stress that their limited treaty networks currently leave them without access to effective mechanisms. OECD countries’ push for mandatory arbitration only deepens these asymmetries, while the Tax Justice Network underlines that arbitration entrenches power imbalances and should be rejected. Instead, the Convention should use this opportunity to “emancipate” dispute resolution from tax treaty bilateralism, creating a universal legal ground for mutual agreement procedures under the UN framework, similar to how information exchange has moved beyond bilateral treaties. During the negotiations it became furthermore clear that many unresolved disputes stem from fundamental disagreement on the fair allocation of the tax base under transfer pricing rules. The Tax Justice Network’s submission therefore highlights that prevention is as vital as resolution: moving away from the separate entity approach and transfer pricing toward unitary taxation and formulary apportionment would not only allocate taxing rights more fairly but also drastically reduce disputes. The protocol is also an opportunity to prohibit the use of investor-state-dispute resolution (ISDS) under investment treaties to deal with tax disputes by agreeing that tax disputes can only be resolved through tax dispute resolution mechanisms under the Convention. In any case, progress depends on shifting negotiations from optional, non-binding language toward a common normative framework under the Convention that guarantees inclusive access, prioritises prevention, and strengthens resource mobilisation for all countries.
Commitments
The commitments of the convention set out the specific obligations that State Parties legally commit themselves to upholding when they ratify the convention.
✒️ See the pre-agreed version of the Commitments▼
From the Terms of Reference adopted by the UN:
Commitments
10. The framework convention should include commitments to achieve its objectives. Commitments on the following subjects, inter alia, should be:
(a) Fair allocation of taxing rights, including equitable taxation of multinational enterprises;
(b) Addressing tax evasion and avoidance by high-net worth individuals and ensuring their effective taxation in relevant Member States;
(c) International tax cooperation approaches that will contribute to the achievement of sustainable development in its three dimensions, economic, social and environmental, in a balanced and integrated manner;
(d) Effective mutual administrative assistance in tax matters, including with respect to transparency and exchange of information for tax purposes;
(e) Addressing tax-related illicit financial flows, tax avoidance, tax evasion and harmful tax practices;
(f) Effective prevention and resolution of tax disputes
Currently negotiating (6)
💸Addressing tax-related illicit financial flows, tax avoidance, tax evasion and harmful tax practices
Last updated: 12 Nov 2025
Explainer🧠
The challenge of addressing tax-related illicit financial flows, tax avoidance, tax evasion, and harmful tax practices lies at the core of global tax justice debates.
Tax-related illicit financial flows occur when multinational corporations shift profits and wealthy individuals hide assets offshore to deliberately separate where economic activities take place from where taxation should occur, depriving countries—particularly in the Global South—of vital revenues. Hidden transactions, undisclosed ownership structures, and selective information exchange allow these practices to flourish.
This undermines not only state revenues but also fuels corruption, organised crime, and erodes public trust. To counter these dynamics, a robust international framework is needed to prioritise transparency and accountability—through automatic exchange of financial information, public registers of beneficial ownership, and public country by country reporting for multinationals.
These measures, often referred to as the “ABC of tax transparency,” are essential to dismantle the structural enablers of illicit financial flows, curb harmful tax abuse, and ensure all countries, regardless of income level, can safeguard their tax sovereignty and mobilise resources for sustainable development.
Negotiation updates 🤝
12 Nov 2025: Countries sharpen focus of commitment while a few attempt to blur it
Since the New York session, countries have decided to separate this element of the TORs into two commitments: one on harmful tax regimes and the other on illicit financial flows and tax abuse. The topic is very important to all countries, but particularly to developing countries, several of which had already argued during the February session that this could be the focus of the second early protocol.
The Africa Group presented a proposal to amend the wording of the commitment, aiming to emphasize not only development but also the implementation of measures to combat illicit financial flows. Following India’s suggestion, several countries supported the idea of narrowing the scope of the commitment to focus specifically on tax-related illicit financial flows.
An intervention by Jamaica reopened the debate on the definition of illicit financial flows, a topic raised in previous sessions and which always seems to cause a fuss. Contrary to the view expressed by some countries — which said the lack of a definition of IFFs was the “elephant in the room” — the term already has a statistical definition recognized within the United Nations system, which was created as the basis for the globally agreed Sustainable Development Goals target to reduce IFFs. It has been reiterated in several documents, where it has been used for many years to describe both flows originating from strictly illegal activities and activities that are socially forbidden and not necessarily unlawful. Cross-border tax abuse by multinational companies is identified as a central element. Still, some countries, such as the Bahamas and Germany, seemed to want to narrow the scope of the discussion and keep tax abuse out.
Another issue discussed concerned the relationship between the transparency mechanisms proposed under this commitment and those appearing elsewhere in the text. Some delegations questioned whether there was overlap or distinction between them. The Secretariat explained that the call for transparency mechanisms, as well as on exchange of information here, came in response to and sought to build upon practices of countries that were already trying to match import and export data to detect potential frauds and manipulations of prices, values, or volumes aimed at underpaying tax. This topic was well received even by countries without an income tax, such as the Bahamas, that might be reliant on import duties.
8 Aug 2025: Scoping discussion during first round of negotiations
Although this topic was not included among the commitments to be discussed in the first round, a series of guiding questions raised by the Secretariat enabled an initial scoping exercise.
Member States agreed that tackling illicit financial flows and harmful tax practices is central to restoring trust in the global tax system. Many Global South representatives stressed the heavy toll of illicit financial flows on their economies, pointing out that corporate profit-shifting, tax havens, and “race to the bottom” incentives deprive countries of vital resources for development.
They called for a comprehensive package under the UN framework convention to curb illicit financial flows, phase out harmful tax competition, and ensure accountability through transparent reporting.
By contrast, some Global North states placed greater emphasis on complementarity with existing instruments and cautioned against over-prescriptive commitments in the convention text. This divergence illustrates a broader tension: while Southern voices push for transformative measures against systemic abuses, Northern counterparts lean towards incremental changes and voluntary coordination
Previous updates (0)
No previous updates
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Analysis💡
Tax Justice Network’s analysis – 14 Oct 2025
From a Tax Justice Network perspective, discussions on illicit financial flows, tax abuse, and harmful tax practices confirm broad recognition of their centrality but also expose sharp divides.
Global South countries stressed the heavy toll of profit shifting, tax havens, and harmful tax competition, calling for binding UN commitments to curb illicit financial flows and ensure accountability through transparency.
By contrast, many Global North states preferred incremental approaches and complementarity with existing OECD tools, resisting prescriptive obligations.
For the Tax Justice Network, genuine progress requires prioritising the creation of key global registries – on beneficial ownership, asset holdings, and public country by country reporting – administered through a UN Centre for Monitoring Taxing Rights or a similar body under the Convention’s Conference of Parties. These are essential first steps to dismantle secrecy and tackle tax-related illicit financial flows.
🤝Effective mutual administrative assistance in tax matters, including with respect to transparency and exchange of information for tax purposes
Last updated: 12 Nov 2025
Explainer🧠
Mutual administrative assistance in tax matters is typically understood to encompass a wide range of cooperative mechanisms designed to combat tax evasion and ensure equitable taxation.
These mechanisms include various forms of exchange of information—such as exchange on request, automatic exchange of information (AEOI), and spontaneous exchange of information—as well as simultaneous tax examinations, tax examinations abroad, assistance in the recovery of tax claims, support in the service of documents, among others.
These and other key transparency measures such as beneficial ownership transparency and public country by country reporting enable tax authorities to access critical financial data, such as bank account details and corporate profit records.
While significant progress has been made in shifting from bilateral to multilateral approaches on mutual administrative assistance, the major challenge remains ensuring inclusiveness and adapting standards to suit the realities of all willing countries, especially low- and middle-income nations, which often lack the resources to fully participate in or benefit from existing frameworks.
The UN Framework Convention on International Tax Cooperation offers a transformative opportunity to establish a truly universal and inclusive system for administrative assistance, prioritizing transparency measures that generate robust data to strengthen global cooperation once the framework is operational, thereby fostering fiscal fairness and supporting sustainable development worldwide.
Negotiation updates 🤝
12 Nov 2025: Discussions expose divide in countries’ experiences with administrative assistance
On Tuesday, countries discussed the commitment on mutual administrative assistance. In tax matters, administrative assistance mainly includes the exchange of information between countries and cross-border assistance in the collection of taxes. The Co-Chairs’ draft text of the commitment proposes language according to which countries shall afford one another the widest measure of mutual assistance while at the same time respecting certain limits, such as confidentiality standards.
African countries generally agreed with the language of the draft. As pointed out by the delegate of Zambia, speaking on behalf of the African Group, mutual assistance is the very backbone of international cooperation in tax. The sharing of relevant information is key in countries’ fight against evasion and aggressive tax abuse and, as such, from a Global South and African perspective, a key element to enable domestic resource mobilisation and achieve sustainable development.
The African Group supported the suggested draft commitment on administrative assistance, which was found to be both high level enough and sufficiently clear to provide a solid foundation for substantive work on the matter under the Convention. The African countries believed the commitment should be framed widely enough to allow future work to be carried out by the Conference of Parties under the Convention to devise rules on all types of administrative assistance, including the exchange of all relevant information needed to enforce national taxes of any kind. The African countries further noted their acceptance that certain confidentiality standards need to be met in relation to the exchange of information. However, such secrecy standards cannot be to the detriment of introducing transparency measures like public country by country reporting, which the African countries believe is a cornerstone of effective and inclusive exchange of information.
Other countries, like Mexico, Japan and the Republic of Korea, were quick to point out the high risk of duplicative efforts, as other international fora and instruments like the OECD’s Global Forum and the Multilateral Convention are seen as sufficiently covering countries’ administrative assistance needs. Unsurprisingly, rather than championing administrative assistance’s potential for domestic resource mobilisation, Switzerland, a notorious guardian of international tax secrets, was keen to stress the need for clear limits to the ‘widest measure’ of administrative assistance. According to Switzerland, any commitment on administrative assistance cannot go beyond the standards set in other relevant fora, like the Global Forum.
Administrative assistance in line with the principles and standards set out by the Global Forum has seen significant expansion in recent years. Its reach is not universal, and especially low-income countries currently do not reap the benefits of administrative assistance. For those countries, it is not simply a matter of ‘signing up’ to the standards imposed on the most advanced tax authorities in the world. As Ghana put it, technical assistance, capacity building and different minimum standards, including on data protection, should be envisioned. The Bahamas had a slightly different take on the matter, urging that the commitment on administrative assistance focus on capacity building and leave the rule building to target other aspects of international tax regulatory reform. The Bahamas noted that as a small island developing state, its limited administrative resources are completely taken up by adopting and administering the various new regimes, like the domestic minimum tax triggered by Pillar Two. Improvement of administrative assistance thereby stands or falls with increasing administrative capacity.
A number of OECD countries questioned the lack of explicit mention of the interaction of the draft language with existing rules under the Global Forum. Austria, for example, wondered whether the purpose of the commitment was to make existing mechanisms for administrative assistance work, or whether the point is to create a self-standing regime on the basis of which countries can engage in administrative assistance. If it is the former, then reference has to be made to the relationship to the Global Forum’s work. In the case of a self-standing rule, this feature needs to be made more explicit so countries know what to expect. The United Kingdom emphasised the need for complementarity and respect for expertise on the matter in other fora. Estonia altogether questioned the addition of the commitment, especially when the Global Forum has quasi-universal reach and has developed international standards on the technical and complex subject of administrative assistance.
Ghana took the floor a second time to correct the common misunderstanding that standards developed in the Global Forum are universal. In reality, half of African countries are not members of the Global Forum, which indicates that adherence to and endorsement of Global Forum standards are neither global nor universal. Furthermore, among those jurisdictions that are members, only a handful exchange information automatically. In many instances, lower-income countries remain outside the regime’s operational reach. Kenya added that for many crucial administrative assistance obligations under the Global Forum, effective assistance is not granted due to the many reservations that have been adopted. On this last point, Belgium wondered whether the purpose of the commitment then is to refuse sovereign states the ability to use certain reservations in the context of administrative assistance.
Brazil’s intervention in the final minutes of the session summarised the Babylonian confusion that surrounds the negotiations on this topic. For certain countries, particularly low-income countries, there are clear problems with the existing rules on administrative assistance. For other countries, the standards on exchange of information and other forms of administrative assistance developed by the Global Forum work well. Many resources have been dedicated to the continuous improvement of these standards, and these countries see little point in duplicating this work, let alone building a new regime from scratch.
In the end, countries may want to focus on the obvious: (1) administrative assistance is a key tool for domestic resource mobilisation in each country at the negotiation table; and (2) not all countries at the negotiation table currently benefit from administrative assistance under the current rules. Accepting those two premises should make it possible for countries to assume the commitment to use the Framework Convention’s governance structure to look into solving this situation. As the Brazilian delegate pointed out, the first step is to agree on a commitment to explore this issue through working groups and exploratory protocols. We may add that high-income countries currently benefiting massively from administrative assistance will have enough opportunities in this process to deliberate on their individual contributions to the common good of global development and prosperity. There is no need to pull the ‘national interest’ brakes just yet.
8 Aug 2025: Scoping discussion during first round of negotiations
Although this topic was not included among the commitments to be discussed in the first round, a series of guiding questions raised by the Secretariat enabled an initial scoping exercise. There was broad recognition that transparency and the exchange of information are essential pillars for effective international tax cooperation. Delegations from the Global South underlined that current mechanisms remain insufficient, particularly as many developing countries lack equal access to beneficial ownership data and timely exchange of financial information. They called for universal and automatic exchange systems under the UN framework, supported by capacity building and fairer participation rules. Some Northern countries also recognised the value of transparency but favoured complementary approaches with OECD standards and stressed that commitments should remain at a high level within the framework convention. The debate thus revealed a divergence between calls for universal, binding commitments versus a preference for more voluntary or protocol-based arrangements
Previous updates (0)
No previous updates
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Analysis💡
Tax Justice Network’s analysis – 14 Oct 2025
From a Tax Justice Network perspective, the initial scoping discussions on administrative assistance and transparency mark an important step toward embedding effective information exchange in the Convention, but they also reveal stark divides.
The broad recognition that transparency and exchange of information are essential pillars is welcome, yet developing countries’ concerns remain acute: current OECD-led frameworks systematically disadvantage them, with unequal access to beneficial ownership data and financial information limiting their ability to tax cross-border wealth.
Calls from the Global South for universal, automatic exchange systems under a UN framework, backed by capacity-building and fair participation, point directly to the reforms needed to level the playing field. However, reluctance from some Northern countries—who prefer complementary reliance on OECD standards and high-level, non-binding commitments—risks entrenching existing inequities.
For the Tax Justice Network, real progress demands moving beyond voluntary arrangements toward binding commitments on automatic exchange of information, global beneficial ownership transparency, and public country by country reporting by multinationals, ensuring all jurisdictions can access critical tax data, close secrecy loopholes, and end the practices that fuel tax abuse and illicit financial flows.
⚖️Fair allocation of taxing rights
Last updated: 11 Nov 2025
Explainer🧠
The allocation of taxing rights is a central issue in international taxation because it determines which country has the authority to tax income arising from cross-border economic activities. This challenge extends beyond corporate taxation to include the taxation of high-net-worth individuals and digital nomads who generate income across multiple jurisdictions.
Current international tax rules, designed a century ago, are increasingly inadequate: they rely on the principle of physical presence, which does not capture the realities of digital businesses operating remotely, and on the separate entity approach, which artificially treats multinational subsidiaries as independent, thereby enabling profit-shifting to low-tax jurisdictions. Moreover, the global network of bilateral tax treaties often entrenches inequalities, as they tend to favor wealthier countries where multinational corporations and affluent individuals are headquartered.
As a result, developing countries—where significant economic activities and consumption occur—are deprived of their fair share of tax revenues, undermining their fiscal sovereignty and ability to fund essential public goods and services.
Negotiation updates 🤝
11 Nov 2025: Text negotiations see attempts to weaken commitment rebutted
The most important commitment in the whole convention is to achieve “a fair allocation of taxing rights” – recognising that the current international rules fail entirely to deliver on this. Day 1 of the Third Session on Mon 10 Nov 2025 covered the draft text on Article 4 which addresses this point. The discussion confirmed the central importance for the Convention of this commitment, and the contours of disagreement were also firmly established.
The starting position in the text is that States should have the right to tax when there is meaningful economic activity in their jurisdiction.
Countries from the global South raised a set of points including a preference for the text to address the breadth of ‘economic activities’ rather than the possibly narrower ‘business activities’. There was also an important drafting clarification, that the three factors in the text indicating an economic link to a jurisdiction, should be listed with ‘or’ rather than ‘and’ – so that any one link is sufficient to establish taxing rights, rather than all three being required.
Some global North countries and some jurisdictions that rank highly on the Corporate Tax Haven Index (notably Singapore and UAE) raised a range of concerns. First, they suggested that the current text reflects the taxing rights of ‘source’ countries (where activity takes place) but not ‘residence’ countries (where the ownership/headquarters of a business may be). This was rebutted by the African Group of countries and others, noting that the criteria proposed are not specific to source or residence and would cover both.
There were also a range of other attempts to weaken the text, by insertion of the following within the commitment to a fair allocation:
– Relief for double taxation (attempts to establish this as a conditioning factor within the fair allocation commitment, so that any attempt to build policy from the allocation commitment would always need to be tempered by the concern to avoid or relieve risks of double taxation
– Other aims, specifically those of ‘tax neutrality’ and ‘tax efficiency’, and also the promotion of international trade, investment and economic growth (again these would temper or even prevent the commitment to a fair allocation from being made active)
– Relationship to other instruments/commitments, including double tax treaties and future protocols (the former certainly intended to limit any meaningful commitment under Article 4)
In each case, these were rebutted as not being appropriate for an Article making concrete the high-level commitment to a fair allocation of taxing rights. For example, there is already a proposed Article elsewhere in the draft on the relationship with other instruments such as double tax agreements.
It was fascinating to see, effectively for the first time in public, the attempts of countries from the global North to argue for the continuation of their unfair allocation of taxing rights. From the outside, this served only to confirm the importance of this Convention, and the central commitment to a fair allocation.
8 Aug 2025: First round of negotiations kicked-off
There was broad acknowledgment that, when non-existent, current mechanisms are slow, costly, and often ineffective, especially across jurisdictions. Many Global South delegations stressed the need for inclusive and preventive mechanisms that reflect their limited capacity, while safeguarding sovereignty and ensuring fairness. They emphasised dispute prevention—through clearer rules and cooperative approaches—as more beneficial than resource-intensive resolution mechanisms. Global North delegations supported commitments at a high level, preferring flexible, non-binding language that avoids constraining states’ discretion. Points of contention included whether the focus should extend to domestic disputes, how to define “timely” resolution given different administrative capacities, and whether commitments should be aspirational or enforceable. Overall, the South favoured stronger, structured safeguards, while the North leaned toward general commitments with optional protocols
Previous updates (3)
21 Jul 2025 Member States make written submissions on Workstream I Co-Lead’s Draft Issue Note
Global South countries highlighted that limited treaty networks and reliance on OECD mechanisms leave them disadvantaged in resolving disputes. They called for a UN-based multilateral system that is independent, accessible, and designed to prevent disputes proactively, rather than relying solely on resolution after conflicts arise. In contrast, many Global North countries supported reinforcing dispute resolution as a way to provide legal certainty and reduce compliance burdens, but placed more emphasis on building on existing mechanisms. Their focus was on efficiency, timeliness, and avoiding duplication, while Global South countries stressed equity and meaningful participation in dispute processes. See the submissions here.
11 Jul 2025 Stakeholders provide input for INC discussions to be held in August 2025
Contributions highlighted the need for dispute resolution mechanisms that are fair, accessible, and especially responsive to the needs of developing countries with limited treaty networks. Some stakeholders proposed moving away from OECD’s Mutual Agreement Procedure, criticized as inaccessible and biased, toward more inclusive multilateral mechanisms under UN auspices. Civil society recommended embedding independence, timeliness, and transparency as standards, and ensuring that dispute prevention mechanisms reduce the risk of double taxation while also protecting against double non-taxation. A recurring theme was that the Convention must empower developing countries by guaranteeing equitable participation in both prevention and resolution processes
27 Jun 2025 Publication of Workstream I Co-Lead Draft Issue Note
The Co-Lead of Workstream I (Ghana) have released a draft issues note. The note highlights that views on the fair allocation of taxing rights remain diverse: some countries emphasize restoring taxing rights eroded by changing business models, while others call for ensuring that all jurisdictions where business activity occurs—whether in supply, demand, or user markets—can share in the taxation of income. It stresses that commitments should balance fairness with principles of economic efficiency, tax neutrality, simplicity, and administrability, while being adaptable to digitalization and evolving business practices. The note invites countries to discuss whether the proposed commitment adequately outlines an approach that recognizes every jurisdiction where business activity takes place, while also clarifying how to determine where such activity occurs in light of digitalization. It also asks whether additional concerns should be addressed in the Framework Convention, given the differing perceptions of what constitutes “fair” allocation of taxing rights across countries. These issues will be discussed at the INC sessions in August 2025.
Analysis💡
Tax Justice Network’s analysis – 14 Oct 2025
From a Tax Justice Network perspective, the negotiations show both encouraging signs of progress and persistent gaps. On the positive side, the principle of fair allocation of taxing rights has clearly moved to the center of the debate. However, substantial gaps remain.
The Global South’s demand for taxing rights aligned with real economic activity directly tackles structural injustices—such as profit shifting, digitalisation loopholes, and the erosion of source-based taxation—that have long deprived them of critical revenues. Meanwhile, the Global North emphasises continuity with the status quo, particularly with OECD-led approaches.
From the standpoint of the Tax Justice Network, progress on fairness will only be meaningful if translated into essential reforms: moving beyond the separate entity approach to end corporate profit shifting through unitary taxation, creating future-proof nexus rules that capture significant economic presence, and rebalancing taxing rights under a multilateral system that corrects treaty asymmetries and adapts to emerging challenges.
Without these issues included in the Convention as such, this commitment risks remaining rhetorical rather than delivering gains for all countries as well as fair redistributive outcomes.
🎩Addressing tax evasion and avoidance by high-net worth individuals and ensuring their effective taxation
Last updated: 11 Nov 2025
Explainer🧠
Domestic tax systems often struggle to effectively tax high-net-worth individuals, leading to growing wealth concentration and undermining public trust in fiscal fairness. International cooperation is essential to tackle this challenge.
Tax havens and loopholes allow the ultra-wealthy to shield billions from taxation, depriving governments of vital revenue. By implementing measures like automatic information exchange and global asset registries, countries can close these gaps, ensure fair tax contributions, and fund essential social programs.
A robust international tax cooperation framework also empowers states to protect their tax sovereignty, enabling them to fairly tax high-net-worth individuals and prevent the erosion of their fiscal authority. Without unified global action, fragmented national policies will remain ineffective to tackle the power of the wealthy to exploit loopholes of the system, perpetuating deep-seated inequities.
Negotiation updates 🤝
11 Nov 2025: Countries discuss commitment text and transparency link on first day of Third Session
Discussions on Article 5, on high-net-worth individuals (HNWIs), began on the afternoon of 10 Nov and continued in the morning of 11 Nov. The existing negotiation text aims to prevent high-net-worth individuals from avoiding or evading taxes through the expansion of exchange of information to new asset types, instruments, and structures used for tax avoidance. It also introduces a paragraph calling on countries to adopt coordinated approaches to ensure the effective taxation of high-net-worth individual.
Several countries – including Brazil, France, Austria, and Peru – emphasised the importance of this article. Brazil underlined that to further develop the concept of effective taxation, as defined in the Terms of Reference, it would be essential to explicitly link it to the principle of progressivity.
Given that the article is predominantly centred on information exchange, many countries observed that exchange of information on high-net-worth individual does not differ significantly from other forms of information exchange, and should therefore be addressed as part of a single, consolidated article – potentially cross-referenced rather than dispersed throughout the text.
Countries from the Africa Group, as well as Iran, proposed removing the qualifier “as such exchange becomes feasible” to strengthen the commitment. Others – including the Bahamas, Japan, the United Kingdom, and Saudi Arabia – raised concerns about potential overlaps of proposed exchange of information mechanisms with existing frameworks.
Discussions also touched upon how to define a high-net-worth individual, given that thresholds and classifications vary widely across jurisdictions and could have implications for implementation. Developing countries, including Brazil and Iran, called for broad and flexible definitions, adaptable to different national contexts. A number of high-income and financial-centre countries sought to weaken the binding nature of the commitments, proposing to replace “agree to adopt coordinated approaches” with “agree to explore.”
A broad group of countries – including Singapore, Côte d’Ivoire, China, the Bahamas, Jamaica, and several EU members (notably Belgium, Hungary, Poland, the United Kingdom, France, Norway, Korea, and Ireland) – stressed that the taxation of individuals remains a domestic matter, cautioning that the current text may go beyond the “high-level” scope of the Convention.
Previous updates (1)
8 Aug 2025: Scoping discussion during first round of negotiations
Although this topic was not included among the commitments to be discussed in the first round, a series of guiding questions raised by the Secretariat enabled an initial scoping exercise.
Discussions highlighted the urgent need to strengthen commitments on the taxation of high-net worth individuals, who often benefit from loopholes in international tax rules and use secrecy jurisdictions to hide or shift wealth. Developing countries in particular emphasised that without effective measures to tax high-net worth individuals, their fiscal space will continue to shrink, undermining the achievement of the Sustainable Development Goals.
Proposals raised include enhanced transparency of ownership and assets, progressive tax measures, and mechanisms to prevent aggressive tax planning and offshore evasion. While Global South voices stressed fairness, equity and the link to sustainable development, some Global North countries preferred to address these matters under existing instruments or to limit the level of detail in the framework convention, leaving specifics to future protocols
Analysis💡
Tax Justice Network’s analysis – 14 Oct 2025
From a Tax Justice Network standpoint, negotiations on the effective taxation of high-net worth individuals expose both the urgency of reform and the risks of deferral. The recognition—led by developing countries—that unchecked avoidance and evasion by high-net worth individuals erodes fiscal space and undermines progress toward the Sustainable Development Goals signals a critical step forward. Proposals on ownership and asset transparency, progressive taxation, and safeguards against offshore abuse point in the right direction, but the reluctance of many Global North countries to embed these commitments directly in the framework convention threatens to weaken their impact. Deferring substance to existing instruments or future protocols risks perpetuating secrecy and inequities that allow the wealthiest to avoid contributing their fair share. Genuine progress requires binding commitments in the convention itself to close loopholes, establish global transparency standards, and, critically, create a global asset registry and strengthen automatic exchange of information mechanisms to ensure that high-net worth individuals are taxed effectively and equitably.
🌱Sustainable development in its three dimensions, economic, social and environmental, in a balanced and integrated manner
Last updated: 7 Nov 2025
Explainer🧠
Taxation is a cornerstone of sustainable development, providing governments with the revenue needed to fund essential public services, reduce inequality, and address global challenges like climate change and poverty.
The Tax Justice Network’s 5Rs framework—Revenue, Redistribution, Representation, Repricing, and Repair—underscores this role: raising sufficient revenue to support public goods, redistributing wealth to reduce inequality, strengthening democratic representation through fair tax systems, repricing harmful activities like carbon emissions to incentivise sustainability, and repairing historical injustices caused by exploitative tax practices.
The UN Tax Convention offers a critical opportunity to advance international tax cooperation, aligning it with instruments like the Rio Conventions on climate, biodiversity, and desertification. By harmonizing global tax policies—such as adopting adequate rules and policies to tackle tax abuse and harmful tax competition—countries can mobilize resources to achieve sustainable development goals, ensuring fiscal systems support both environmental resilience and social equity.
Negotiation updates 🤝
8 Aug 2025: First round of negotiations in NYC kicked-off
Member States converged on the importance of linking tax cooperation to sustainable development across economic, social, and environmental dimensions, but with different emphases. Delegates from developing regions insisted that commitments move beyond abstract alignment with the Sustainable Development Goals toward concrete measures, including tackling harmful tax practices, financing public services, and capacity-building in tax administrations. For them, fair taxing rights are a precondition to achieving sustainable development. Global North countries were generally supportive of high-level commitments but less prescriptive on implementation. Civil society actors reinforced the urgency of scaling up resources, highlighting the large climate and development finance gaps, and called for taxing polluters and the wealthy as a matter of equity and effectiveness
Previous updates (3)
21 Jul 2025 Member States make written submissions on Workstream I Co-Lead’s Draft Issue Note
On sustainable development, Global South countries pressed for the commitment to be operationalized, linking tax cooperation directly to mobilizing resources for development, tackling financing gaps, and integrating equity into international rules. They argued that economic, social, and environmental dimensions must be balanced, with explicit recognition of developmental needs. Global North countries, while supportive of the inclusion of sustainable development language, preferred using existing UN formulations, keeping the text general rather than prescriptive. Their concern was to avoid reopening debates on definitions, whereas Global South countries sought stronger and more actionable commitments. Read the submissions here.
11 Jul 2025 Stakeholders provide input for INC discussions to be held in August 2025
Stakeholders consistently called for strong alignment of tax cooperation with the 2030 Agenda. Civil society organizations urged embedding explicit commitments to use international tax rules to advance climate justice, education, and financing for sustainable development. Proposals included sub-commitments on progressive environmental taxation and climate finance, ensuring it is additional and grant-based. Academic voices also pointed to integrating sustainability indicators into the monitoring framework. The emphasis was on making sustainable development not just a principle, but a concrete driver of commitments in the Convention
27 Jun 2025 Publication of Workstream I Co-Lead Draft Issue Note
The Workstream I Co-Lead (Ghana) draft issues note (June 2025) addresses the proposed commitment on sustainable development. The commitment recalls the language in the Terms of Reference, urging states to pursue international tax cooperation approaches that contribute to achieving sustainable development in its three dimensions—economic, social, and environmental—in a balanced and integrated manner. The note highlights that this framing is already well understood in the UN system, but invites countries to consider whether additional aspects should be incorporated, such as more explicit recognition of the ways international tax rules can support or hinder sustainable development goals. The Committee is therefore asked to discuss whether the draft language is sufficient, or whether further elements should be added to strengthen the link between tax cooperation and the broader 2030 Agenda.
Analysis💡
Tax Justice Network’s analysis – 14 Oct 2025
From a Tax Justice Network perspective, the negotiations on sustainable development reflect encouraging recognition of its centrality to international tax cooperation but expose a gap between rhetoric and actionable commitments.
Developing countries rightly stressed that without concrete reforms—curbing harmful tax practices, ensuring fair taxing rights, and mobilising revenues for public services and climate adaptation—the promise of the Sustainable Development Goals will remain hollow. Civil society amplified this urgency, pointing to vast financing gaps and calling for progressive measures such as taxing polluters and the ultra-wealthy.
Yet many Global North countries leaned toward keeping references at a general level, resisting prescriptive obligations or binding mechanisms. For the Tax Justice Network, progress requires going beyond high-level alignment: embedding enforceable rules that make sustainable development the operational benchmark of tax cooperation. This includes guaranteeing that global tax rules serve as a structural enabler of climate and environmental justice, economic and social rights, and the financing of essential public goods.
❤️Effective prevention and resolution of tax disputes
Last updated: 3 Nov 2025
Explainer🧠
The absence of universally agreed dispute prevention and resolution mechanisms for tax disputes remains a critical gap in the current international tax architecture. This lack of standardised processes allows multinational corporations and high-net-worth individuals to exploit inconsistencies across jurisdictions. Fragmented bilateral agreements and limited multilateral frameworks, such as those under the OECD, often exclude low- and middle-income countries, leaving them vulnerable to aggressive tax planning and unable to resolve disputes effectively. The latter creates also a lot of uncertainty for tax payers. The UN Framework Convention on International Tax Cooperation offers a vital opportunity to address this gap by establishing a universal, inclusive platform that prioritizes equitable dispute prevention and resolution mechanisms. By fostering transparent and simple multilateral standards, the UN Framework Convention can ensure all countries, regardless of economic capacity, have a voice in shaping fair tax policies, reducing conflicts, and promoting fairness.
Negotiation updates 🤝
8 Aug 2025: First round of negotiations kicked-off
Discussions highlighted a divide between perspectives from the Global South and the Global North. Developing countries emphasised that fair allocation of taxing rights is essential to secure domestic resources for health, climate, and social protection systems. They argued that taxing rights should follow where economic activity takes place, correcting long-standing imbalances in the international tax system. By contrast, some developed countries acknowledged fairness but stressed the importance of legal certainty, simplicity, and avoiding disruption to trade and investment. While there was broad agreement on the principle, views diverged on how concretely fairness should be defined and operationalised, with the South pushing for stronger redistributive outcomes and the North emphasising administrability and efficiency.
Previous updates (3)
21 Jul 2025 Member States make written submissions on Workstream I Co-Lead’s Draft Issue Note
Views on fair allocation revealed a clear divide between regions. Many Global South states stressed the need to restore taxing rights that have been eroded by digitalisation and outdated rules, arguing that all jurisdictions where business activity occurs—production, demand, and user markets—should share in taxation. They cautioned against vague notions of “fairness” that could reinforce existing asymmetries. By contrast, several Global North states acknowledged the principle of fairness but emphasised economic efficiency, trade neutrality, and administrative simplicity. They preferred to avoid definitions that could open broader redistributive debates, and focused on preserving stability of current rules.
11 Jul 2025 Stakeholders provide input for INC discussions to be held in August 2025
Stakeholders highlighted that achieving a fair allocation of taxing rights is central to the Convention. Civil society organizations, including the Global Alliance for Tax Justice, called for commitments ensuring that all jurisdictions where business activity occurs—whether in production, demand, or user markets—can share in taxing the income generated. They stressed the need to reverse the erosion of taxing rights under digitalized business models and warned against perpetuating OECD-style transfer pricing rules that have failed to secure revenues for developing countries. Proposals emphasized anchoring the allocation of rights in economic substance and value creation, while also safeguarding principles of efficiency, simplicity, and administrability to ensure rules remain effective as business models evolve
27 Jun 2025 Publication of Workstream I Co-Lead Draft Issue Note
The Workstream I draft issue note outlines discussions on the commitment to strengthen prevention and resolution of tax disputes. Litigation of cross-border tax disputes is often costly, slow, and may still leave risks of double taxation unresolved, particularly for developing countries with limited treaty networks. The note suggests commitments could emphasize establishing mechanisms that are fair, independent, accessible, and effective in providing timely outcomes for both taxpayers and tax authorities. These measures aim to improve legal certainty, reduce compliance burdens, and support domestic resource mobilization. Countries are invited to consider whether the proposed elements adequately address these concerns, whether they provide sufficient support for the early protocol on dispute resolution, and if additional issues should be reflected in the Framework Convention
Analysis💡
Tax Justice Network’s analysis – 14 Oct 2025
From the Tax Justice Network perspective, negotiations on dispute prevention and resolution highlight the huge gaps faced by jurisdictions with small or no treaty networks, which leaves them unable to resolve disputes that are often costly and inaccessible under current mechanisms. The Tax Justice Network emphasises that prevention must be the priority: simplifying rules, moving toward unitary taxation to reduce the root causes of disputes, and creating inclusive, transparent mechanisms under the Convention (for example via a dispute resolution body under the COP) that ensure all countries have fair access. The UN Model’s emerging norms—such as limiting the role of investment treaty arbitration when it undermines tax treaty intent—are promising precedents. However, many Global North delegations still favour non-binding, high-level language and optional mechanisms, and tend to prioritize options like arbitration, which risk reinforcing power asymmetries in the procedure but also privilege Global North country interpretations of transfer pricing and other rules on the cross-border allocation of the tax base. The Tax Justice Network therefore advocates using the opportunity of the Convention to establish a common normative ground for resolving cross-border disputes in function of the principles of the framework, including resource mobilisation, so that dispute systems strengthen certainty, simplicity and fairness.
To be negotiated
Preamble
A preamble is the introduction to the convention. It sets the spirit of the convention and guides how it should be interpreted.
✒️ See the pre-agreed version of the Preamble ▼
From the Terms of Reference adopted by the UN:
Preamble
6. The text of the framework convention should reflect, inter alia, the following General Assembly resolutions:
(a) 78/230 of 22 December 2023 on the promotion of inclusive and effective international tax cooperation at the United Nations
(b) 77/244 of 30 December 2022 on the Promotion of inclusive and effective international tax cooperation at the United Nation
(c) 70/1 of 25 September 2015 entitled “Transforming our world: the 2030 Agenda for Sustainable Development”
(d) 69/313 of 27 July 2015 on the Addis Ababa Action Agenda of the Third International Conference on Financing for Development
To be negotiated
Objectives
The objectives of the convention are statements of what the convention aims to achieve.
✒️ See the pre-agreed version of the Objectives▼
From the Terms of Reference adopted by the UN:
Objectives
7. A United Nations framework convention on international tax cooperation should include a clear statement of its objectives. In that regard, it should:
(a) Establish fully inclusive and effective international tax cooperation in terms of substance and process;
(b) Establish a system of governance for international tax cooperation capable of responding to existing and future tax and tax-related challenges on an ongoing
basis;
(c) Establish an inclusive, fair, transparent, efficient, equitable and effective international tax system for sustainable development, with a view to enhancing the
legitimacy, certainty, resilience and fairness of international tax rules, while addressing challenges to strengthening domestic resource mobilization.
To be negotiated
Principles
The principles of the convention serve as rules-of-thumb that guide how the specifics of the convention should be interpreted and implemented.
✒️ See the pre-agreed version of the Principles▼
From the Terms of Reference adopted by the UN:
Principles
8. A United Nations framework convention on international tax cooperation should include a clear statement of the principles that guide the achievement of its objectives.
9. Efforts to achieve the objectives of the framework convention therefore should:
(a) Be universal in approach and scope and should fully consider the different needs, priorities, and capacities of all countries, including developing countries, in particular countries in special situations;
(b) Recognize that every Member State has the sovereign right to decide its tax policies and practices, while also respecting the sovereignty of other Member States in such matters;
(c) Be aligned, in the pursuit of international tax cooperation, with States’ obligations under international human rights law;
(d) Take a holistic, sustainable development perspective that covers in a balanced and integrated manner economic, social and environmental policy aspects;
(e) Be sufficiently flexible, resilient and agile to ensure equitable and effective results as societies, technology and business models and the international tax cooperation landscapes evolve;
(f) Contribute to achieving sustainable development by ensuring fairness in allocation of taxing rights under the international tax system;
(g) Provide for rules that are as simple and easy to administer as the subject matter allows;
(h) Ensure certainty for taxpayers and governments;
(i) Require transparency and accountability of all taxpayers
To be negotiated
Capacity building
The capacity building articles of the convention specify…
✒️ See the pre-agreed version of Capacity Building▼
From the Terms of Reference adopted by the UN:
Capacity-building
11. Inclusive and effective participation in international tax cooperation requires procedures that take into account the different needs, priorities and capacities of all countries to meaningfully contribute to the norm-setting processes, without undue restrictions, and support them in doing so, including giving them an opportunity to participate in agenda-setting, debates and decision-making, either directly or through country groupings, according to their preference.
12. The framework convention therefore should include provisions regarding institutional mechanisms to support Member States, especially developing countries, in their efforts to build capacity on relevant international tax practice and related issues to ensure that they have adequate capacity to participate effectively in international tax cooperation and to implement the framework convention.
To be negotiated
Other elements
The other elements of the convention…
✒️ See the pre-agreed version of Other Elements▼
From the Terms of Reference adopted by the UN:
Other elements
13. The framework convention should also include, inter alia, the following additional substantive and procedural elements: definitions; relationship with other agreements, instruments and domestic law; review and verification; exchange of information (for implementation of the framework convention); data collection and analysis; financial resources; conference of the parties; secretariat; subsidiary bodies; dispute settlement mechanisms; and procedures for amendments to the framework convention and adoption of protocols; and final provisions.
To be negotiated
Approaches and timeframes
The approaches and timeframes of the convention set out the specific obligations that State Parties legally commit themselves to upholding when they ratify the convention.
✒️ See the pre-agreed version of Approaches & Timeframes▼
From the Terms of Reference adopted by the UN:
Approaches and timeframes for negotiation
18. The framework convention should be elaborated by a Member State-led negotiating committee. The intergovernmental negotiating committee would meet in
2025, 2026 and 2027 for at least three sessions per year, of a duration of no more than 10 working days per session and complete its work and submit the final text of the framework convention and of the two early protocols to the General Assembly for its consideration in the first quarter of its eighty-second session.
19. The bureau of the intergovernmental negotiating committee should consist of a Chair, 18 Vice-Chairs and a Rapporteur, elected on the basis of equitable geographical
representation.
20. Member States should be fully engaged in the negotiation of the framework convention and endeavour to ensure continuity in their representation.
21. International organizations, civil society and other relevant stakeholders are encouraged to contribute to the work of the intergovernmental negotiating committee
in accordance with established practices.
22. Throughout its work, the intergovernmental negotiating committee should take into consideration the work of other relevant forums, potential synergies and the
existing tools, strengths, expertise and complementarities available in the multiple institutions involved in tax cooperation at the international, regional and local levels.
To be negotiated
Resources
The resources of the convention specify…
✒️ See the pre-agreed version of the Resources▼
From the Terms of Reference adopted by the UN:
Resources to support the work of the intergovernmental negotiating committee
23. The Secretary-General should be requested to provide the intergovernmental negotiating committee with the necessary facilities and resources, including a technical secretariat from the Department for General Assembly and Conference Management and a substantive secretariat from the Department of Economic and Social Affairs, to support its work.
24. Member States and other relevant stakeholders in a position to do so are encouraged to assist in ensuring the full and effective participation of developing countries, including in particular the least developed countries, in the negotiation of the framework convention, including by covering travel and local expenses and through capacity-building.
To be negotiated
🛒 “Who wants what?” database
Explore our database below summarising what countries have said they want in negotiations, sessions and in written submissions. You can browse by topics and countries.
View larger version in new tab↗
✊Strengthening the convention with the ABC’s of tax justice
Many of the pre-negotiations terms that countries agreed in the Terms of Reference are based on the “ABC’s of tax justice” policies. These are policies long-championed by campaigners and leading experts from around the world, and are designed to reprogramme our tax systems to work for everyone equally, not just the superrich.
Click on each tax justice policy below to learn more about it and see how the UN tax convention must deliver on it.
📬Automatic exchange of information
What is it? ℹ️
Automatic exchange of information is a data sharing process designed to expose corporations and individuals whenever they hide money in order to appear less wealthy to their governments and underpay tax.
The problem 🚨
The majority of wealth held offshore today is currently hidden from tax authorities. Wealthy individuals use banking secrecy to hide their assets from the authorities and the rule of law, shirking their responsibilities to the government and their fellow citizens.
Automatic exchange of information measures adopted in recent years have stopped the situation from getting worse, but they haven’t alleviated the on-going damage.
States are losing $145 billion a year to offshore tax evasion related to financial wealth alone.
This is hindering the ability of states to meet their obligation to raise the maximum available resources needed for the realisation of human rights, as well as their ability to achieve the Sustainable Development Goals.
The solution💡
Evidence shows automatic exchange of information measures do work, can recover billions in tax lost each year, and support states’ obligations to raise the maximum available resources needed towards human rights – but only if implemented inclusively and without loopholes.
International cooperation on a UN tax convention must:
🔑Ensure access to low and middle income countries
Unnecessarily exclusionary reciprocity requirements prevent many countries from participating in automatic exchange today. A principle of differentiation can address this disparity in taxing rights and ensure all countries can access the information they need.
💎Expand asset coverage
Tax evaders are increasingly utilising asset types not covered by existing automatic exchange of information measures to hide offshore wealth. It is vital to encompass all relevant financial and non-financial assets that could be used to hide wealth and income from tax authorities, like crypto-assets and real estate.
⚖️Ensure accountability
Authorities should publish aggregate, bilateral data on the value of financial accounts and other assets subject to information exchange along with the equivalent values as declared by taxpayers to their home authorities, to ensure public accountability for progress.
🏛️Use a whole-of-government approach
Opportunities to combat money laundering and illicit financial flows are currently being missed by restrictions on the use of exchanged information. Tax authorities should be permitted to share the data they receive with financial intelligence units and other law enforcement agencies to serve broader objectives.
🕵️♀️Beneficial ownership transparency
What is it? ℹ️
A beneficial owner is the real person, made of flesh and blood, who truly owns, controls or benefits from a legal vehicle. Transparency of beneficial owners makes sure that criminals and the wealthiest are held to the same level of transparency and accountability as everybody else.
The problem 🚨
Public access to beneficial ownership information prevents financial crimes, supports healthy markets, and upholds democracy and the rule of law. While beneficial ownership registries have expanded over the last 10 years, no country
has achieved full transparency as of 2025.
Anti-transparency interests are now attempting to invoke the judicial system to further undermine beneficial ownership registries by elevating individual privacy above the public’s right to information in a narrow interpretation of human rights.
Leaks like the Panama and Paradise papers expose how complex ownership structures allow drug smugglers, corrupt officials, and wealthy individuals use complex ownership structures to underpay tax and hide illicit wealth, undermining human rights and sustainable development by enabling crime and corruption.
Under international human rights law, the right to freedom of expression includes access to information, which must extend to beneficial ownership data to detect and deter illicit financial flows, tax abuse, and corruption.
The solution💡
Beneficial ownership registries expose corruption, protect democracy, reveal tax abuse, and support environmental protection. The UN tax convention should require countries to establish registries that:
✅Cover all legal vehicles with no exceptions
Any legal vehicle/entity excluded from registration can be exploited to conceal ownership. All types, including companies, trusts, partnerships, foundations, and Anstalts, whether legal persons or not, must be required to register beneficial ownership.
📇Collect sufficient details on all beneficial owners
Definitions must be broad enough to capture all relevant individuals who own, control or benefit from legal vehicles, without thresholds. Information must fully identify individuals, be regularly updated, and ensure it is accurate (verified).
🌐Are publicly accessible
Legal and beneficial ownership data should be free and available in open data format to ensure access for civil society, investors, authorities and journalists.
🔄Interconnect with asset registries
Asset beneficial ownership is key to combatting cross-border crime, and to measuring and addressing inequality by taxing wealth. A Global Asset Registry would help fight against financial crime at the global level to benefit all countries.
💸Country by country reporting
What is it? ℹ️
Public country by country reporting is an accounting practice designed to expose a multinational corporation whenever it shifts its profit into tax havens to pay less tax than it should.
The problem 🚨
Every year, multinational corporations shift 40 per cent of their profits into tax havens, costing states an estimated US$348 billion in lost tax revenue a year.
This is hindering the ability of states to meet their obligation to raise the maximum available resources needed for the realisation of human rights.
It also hinders states’ extraterritorial obligations to ensure that their actions, laws and policies do not adversely affect the human rights of other territories.
Public country by country reporting was meant to curb this problem. But the OECD left the “public” part out of its global standard for country by country reporting, making the standard less effective. Profit shifting has actually gone up since the standard was introduced.
The solution💡
1 out of every 4 dollars lost to profit shifting today can be prevented by making country by country reporting data public. Making the data public can also hold states accountable to their human rights obligations and their extraterritorial obligations.
Investors responsible for trillions of dollars have repeatedly called for the data to be made public, and several multinational corporations have voluntarily published their data. International cooperation on the UN framework convention must:
🌐Make the data public
Require multinational corporations to make their country by country reports public.
🗺️Require a full country-level breakdown at the company level
The data must clearly show each company’s activities and tax paid in every country where it operates.
⬇️Reduce thresholds for multinationals
Many lower income countries have smaller multinationals operating in their jurisdictions, which are often exempt under current standards that only apply to companies with a turnover of €750 million. This means that smaller MNCs are free to engage in profit-shifting practices within lower income countries without hindrance.
✅Apply requirements to all jurisdictions
Country by country reporting requirements often limit reporting to “high-risk” jurisdictions, yet significant profit shifting occurs in OECD countries that are excluded from these lists.
⭐Adopt Global Reporting Initiative (GRI) standards
The voluntary GRI Tax Standard is the world’s gold standard for public country by country reporting. In 2024 Australia became the first country to align its legislation with the standard.
🌍Cross-border services
What is it? ℹ️
The taxation of income from cross-border services in today’s digitalised and globalised economy exposes the failure of outdated tax rules — and demands a bold, proven alternative: unitary taxation with formulary apportionment.
The problem 🚨
In today’s globalised and digitalised world, the economy has outgrown traditional tax rules. It is no longer feasible to treat tax as a purely domestic matter, as companies operate across borders—and often without any physical presence in a country.
Current rules fail to trigger taxing rights where no physical presence exists, making it difficult to tax income from services delivered across borders. This failure widens inequality, undermines human rights, and limits countries’ ability to raise public revenue. The taxation of cross-border services offers a critical chance to fix some of the outdated flaws in the international tax system.
The solution💡
One of the early protocols currently being negotiated around the UN tax convention is on digital services. The main objective of this protocol should be to support domestic revenue mobilisation by providing for a fair allocation of taxing rights to where services are delivered and users are located.
In order to accomplish this goal, the protocol should:
✅Encompass a broad scope of services
Focusing on all cross-border services, rather than only digital, broadens taxing rights and reduces complexity.
💱Incorporate unitary taxation with formulary apportionment
Calculating the profits of multinationals as unitary entities and allocating those profits by formula offers a clear, workable path to a fairer share of taxing rights —especially for lower income countries.
⚖️Prioritise simplicity and fairness
The protocol should focus on simplicity and ease of administration, to tackle current problems and lay the groundwork for more ambitious reform and a future-proof, equitable system.
👷Focus on real economic activity
The trigger for a taxable presence should be simple to define and resistant to manipulation. Focusing on real economic activity is a clearer path to determining where services are delivered and users are located.
💱Formulary apportionment under unitary taxation
What is it? ℹ️
The taxation of income from cross-border services in today’s digitalised and globalised economy exposes the failure of outdated tax rules — and demands a bold, proven alternative: unitary taxation with formulary apportionment.
The problem 🚨
Profit shifting for the purpose of tax abuse by multinational companies is a social menace. Every year, multinational corporations shift around 40 per cent of their profits to tax havens, costing countries an estimated US$348 billion in lost tax revenue.
The revenue lost by governments as a result of this widespread practice undermines public services, erodes tax sovereignty, fuels inequality, and threatens the human rights of people and communities.
All countries deserve a fair allocation of taxing rights that reflects real economic activity. We could sharply curb profit shifting with the obvious alternative approach to corporate taxation: taxing profits in the location of the underlying real economic activity.
The solution💡
Unitary taxation with formulary apportionment promotes fairer taxing rights and helps prevent disputes by taxing profits where real activity occurs—not where companies choose to declare them. Each year, over a trillion dollars in profit is shifted to low-tax jurisdictions. This approach removes much of the manipulation and conflict built into current transfer pricing rules. The UN Framework Convention on International Tax Cooperation is the place to implement it. It should:
📍Treat multinationals as unitary entities
Multinational corporations and transfer pricing remain major challenges in today’s tax system. Recognising them as single global businesses would simplify taxation and block many methods used to underpay tax.
🍰Apportion profits based on real economic activity
Global profits should be shared between countries where a multinational operates, using a simple formula that reflects the scale and nature of its real economic presence — capturing both supply-side factors (like employment) and demand-side factors (like sales).
🔎Create global transparency mechanisms
Tools like a central public database for country-by-country reports and a global asset register will help countries make informed decisions, tackle tax abuse, and enable citizens to hold governments and companies accountable for fair taxation.
🪙Establish an ambitious minimum tax rate
A global minimum effective corporate tax rate is crucial to ending the race to the bottom and ensuring a fairer share of global taxing rights.
❤️Prevention and resolution of tax dispute
The problem 🚨
The lack of a globally inclusive and effective international tax system leads to inevitable cross-border tax disputes between countries, and with taxpayers who are economically active in multiple jurisdictions.
Cross-border tax disputes are complex, costly, and time-consuming to resolve. Solutions rely heavily on bilateral tax treaties, but many countries in the Global South have few such agreements and are often left without access to effective remedies. Dispute resolution mechanisms based on tax treaties are opaque, overly complex, and not designed to meet the needs of lower income countries.
The solution💡
Prevention first
Adopt substantive tax rules that are less prone to conflict in interpretation and application.
💱Unitary taxation with formulary apportionment
Treating multinationals as unitary entities would support fairer allocation of taxing rights and help prevent disputes, as it is less prone to conflict than current transfer pricing.
🔎Transparency measures
A central body should publish dispute outcomes and decisions across countries in the Convention, ensuring consistent rule interpretation and avoiding repeated disputes.
Resolution next
Ensure all countries have access to inclusive and effective procedures for resolving disputes when they arise.
🌍Move away from bilateralism
Establish global rules and multilateral mutual agreement procedures that replace the reliance on bilateral dispute resolution, which is prone to power imbalances between countries.
⚖️Publish settlements
Key information about tax dispute settlements must be made public to promote transparency, ensure consistent application of the rules, and prevent repeat disputes on identical issues.
Mandatory procedures
While some aspects of the dispute resolution protocol may be optional, a fair and inclusive process for resolving disputes under the Convention must be mandatory.
📢Social justice in the convention
The UN tax convention is a powerful vehicle for several justice issues, like gender rights and climate justice. Click on a social justice issue below to learn more about how it connects to the UN tax convention.
♀️Gender
The flaws of the global tax system disproportionately harm women. Cross-border tax abuse by multinationals and wealthy individuals reduces public revenue and increases reliance on regressive indirect taxes. These taxes fall most heavily on women, who are overrepresented among the poorest.
The unfair distribution of taxing rights also deprives developing countries of their fair share of cross-border revenue, forcing them to rely on regressive taxation and shifting the burden further onto women. At the same time, underfunding of public goods and services such as childcare continues to disadvantage women.
In the Compromiso de Sevilla, state parties “reaffirm the imperative of achieving gender equality” and commit to “advance discussions on gender-responsive taxation” (paragraph 27(g)). The UN tax convention is the vehicle for designing an international tax system that does not place unfair burdens on women and instead advances gender equality.
♻️Climate
The Un tax convention is a historic opportunity to reshape global tax rules so they deliver the resources urgently needed to confront climate breakdown.
The UN Tax Convention must embed climate justice and sustainable development at its core. Too often, tax and climate talks have been treated as separate silos, weakening both. The convention is our chance to correct this failure and ensure tax justice becomes a lifeline for climate justice.
🍎Education
The global education crisis is fuelled by corporate capture, lobbying pressure, and international tax rules that undermine countries’ fiscal sovereignty. While schools are underfunded and teachers are underpaid, billions in potential revenue are lost each year to tax abuse by multinationals and the super-rich. These are stolen futures that can and must be reclaimed.
Delivering tax justice through the UN tax convention is a golden opportunity to protect every child’s right to quality public education. It is also how we ensure every educator is valued, supported, and treated with dignity.
🕊️Human rights
Failures in international tax cooperation deprive states of the revenues they need to meet their human rights obligations. Current global tax rules block many low- and middle-income countries from aligning their tax systems with those obligations. Governments must cooperate, not undermine each other, in mobilising the maximum available resources to guarantee the rights to health, education, and social protection. When these services are underfunded, women are forced to absorb the gaps through unpaid care work.
Principle 9(c) of the UN tax convention’s Terms of Reference requires negotiators to ensure that international tax cooperation is aligned with states’ obligations under international human rights law. In line with this principle, states must create an international environment that enables human rights-based tax policies at home. That means fair global tax rules that allow governments, especially in low- and middle-income countries, to raise sufficient revenues to realise rights for all.
ℹ️FAQs
General
What is a framework convention?
A framework convention is a type of international agreement that sets the foundations for future rules and institutions. It does not provide all the details at once but creates the basic structure on which stronger, more detailed laws can be built over time.
The United Nations Framework Convention on International Tax Cooperation (UNFCITC) will play this role for tax. It will lay the groundwork for a new global system of tax rules and institutions, similar to how the UN Framework Convention on Climate Change became the foundation for today’s climate agreements.
Building such a system takes time, but the first steps are critical. Decisions made in the next three years will shape what is, and is not, possible in international tax cooperation for decades to come.
How does the UN tax convention benefit all countries?
Weak and fragmented international tax cooperation harms all countries. Although countries may disagree on how to share costs and benefits, they all gain more from full cooperation than from partial or none at all.
In today’s interdependent economy, no country can enforce its tax rules on cross-border activity without cooperation. Multilateralism is essential to protect tax sovereignty.
The benefits would be greatest if as many UN member countries as possible ratify a single, ambitious Convention. No other forum has achieved this. The challenge is to design an agreement that is widely acceptable but still ambitious enough to deliver effective multilateralism.
What’s wrong with existing standards? Why do we need to universal and inclusive ones?
Current international tax standards are not truly global. While cooperation has improved in the last decade, key mechanisms like automatic information exchange still exclude many countries, often those most in need.
For example, only 125 countries take part in the OECD’s Common Reporting Standard, leaving nearly 70 UN members outside. Rules requiring immediate reciprocity disadvantage lower-capacity countries, reducing the benefits both for them and for countries already in the system. The result is an unequal and less effective system.
The UN Tax Convention offers the chance to create universal standards, adaptable to different capacities, so that all countries can benefit and global cooperation can reach its full potential.
How will the convention benefit Global North countries, who are often more sceptical about it?
Although often seen as a win for the Global South, the UNFCITC offers important advantages for all countries committed to effective tax cooperation.
For example, Australia has adopted a world-leading standard for public country by country reporting. The Convention gives it a platform to push for global uptake of this practice.
Similarly, EU countries facing deadlock from unanimity rules could use the UN framework to advance reforms globally. In that setting, dissenters may object but cannot veto progress. The Convention therefore provides Global North countries with a way to scale up their own reforms and move beyond regional gridlock.
Technical
Does the UN tax convention duplicate existing work?
Decision-making procedures in the United Nations are consensus-oriented, but do not exclude the possibility of majority voting when time requires it and the possibility of super-majority votes for the most important decisions. The rules of procedure of the subsidiary bodies of the General Assembly are well established and experience shows that it is not appropriate to grant any country veto power, which is what happens when consensus is adopted as the sole rule for decision-making.
While some UN Conventions have indeed been adopted by consensus, this has predominantly occurred during significant political gatherings, such as the Earth Summit in Rio de Janeiro in 1992. Here, landmark conventions like the United Nations Framework Convention on Climate Change (UNFCCC), the Convention on Biological Diversity (CBD), and later in similar contexts, the United Nations Convention to Combat Desertification (UNCCD), were all adopted by consensus. However, when it comes to Ad Hoc Committees or other subsidiary bodies of the General Assembly, the experience has been markedly different.
The United Nations Convention on the Law of the Sea (UNCLOS) provides a pertinent example. Despite starting with the aim of achieving consensus, the negotiations for UNCLOS were fraught with disagreements, particularly over issues like the deep seabed and economic zones. Ultimately, after years of negotiation, when consensus could not be reached at the Third United Nations Conference on the Law of the Sea, the convention was adopted by a recorded vote in 1982, reflecting the failure of consensus as a decision-making mechanism in this context.
Other examples are also illustrative in this regard. For instance, the Ad Hoc Committee for the Arms Trade Treaty (ATT) attempted to adopt the treaty by consensus in 2013 but failed due to objections from a few states, leading to the treaty’s adoption through a vote in the General Assembly. Similarly, the Ad Hoc Committee on Measures to Eliminate International Terrorism has often struggled with consensus, given the contentious nature of defining terrorism, frequently resorting to alternative decision-making mechanisms.
More recently, the experience of the Intergovernmental Negotiating Committee on Plastic Pollution illustrates similar challenges. This committee, tasked with developing an international legally binding instrument on plastic pollution, has faced significant hurdles in achieving consensus among member states. The negotiations, ongoing with sessions from 2022 to 2024, have shown that while there is a common goal to address plastic pollution, the diversity of interests, particularly around production, waste management, and binding versus voluntary measures, has made consensus elusive. Despite the ambition to conclude by the end of 2024, the process has seen multiple sessions where consensus was not achieved on key elements, suggesting that if a final agreement is reached, it might require reverting to majority voting or other decision-making methods.
These examples underscore that, outside of major, well-orchestrated summits, consensus often proves elusive in the detailed, ongoing work of UN subsidiary bodies, leading to a reliance on majority voting to move forward with international agreements.
What does the “framework-protocol” approach mean?
The framework–protocol approach is often described as the opposite of a piecemeal approach to international law.
In a piecemeal approach, governments respond to a larger problem by regulating individual aspects separately. This can leave gaps and create inconsistencies.
The framework–protocol approach begins instead with a framework convention that sets out shared principles, objectives and actionable commitments. Detailed protocols are then added over time to address specific issues, ensuring they remain connected and coherent as part of one overall system.
Can a country join the protocols without first ratifying the Convention?
No. Under the framework–protocol approach, only countries that have ratified the main Convention can become parties to its protocols. This design ensures that all countries participating in the protocols are already committed to the Convention’s principles. This provides consistency and coherence when interpreting and implementing their rights and obligations.
What should be included in the Convention itself, and what should be left to the protocols?
There are different views on how much substance should go into the United Nations Framework Convention on International Tax Cooperation (UNFCITC) and how much should be left to its protocols.
Some argue that the Convention should include strong commitments across key areas, since its obligations bind all countries that ratify it, whether or not they later join protocols. Others caution that making the Convention too ambitious could slow negotiations or discourage ratification.
The challenge is to balance ambition with feasibility. The Convention should set out a widely supported governance framework while also embedding meaningful obligations from the start. Protocols can then build on this foundation with more detailed and ambitious measures.
Negotiations
Is establishing an effective UN tax convention a realistic goal?
Although the current global political environment does not particularly highlight values of multilateralism and cooperation, international tax cooperation continues to gain momentum through ongoing negotiations. This persistence is due to a convergence of interests where capital-exporting countries aim to prevent a chaotic array of tax rules that could complicate international business for multinationals, while capital-importing countries seek to collect more tax revenue for national development. Both groups share a common goal to curb cross-border tax abuses, which result in substantial revenue losses. The implementation of the OECD’s two-pillar agreement, particularly Pillar 1, seems unlikely, especially following recent political changes in the U.S. Therefore, the negotiation of the UNFCITC presents the most viable opportunity for establishing a universal framework that can lead to significant progress in this area.
Is the US withdrawal from UN tax talks a fatal blow to the Convention?
No. The United States could still benefit from a widely accepted UN Tax Convention. A stable, uniform set of global rules would spare American multinationals from facing a patchwork of unilateral tax measures around the world.
History shows the United States has often shifted its position when global standards aligned with its interests. The OECD’s Common Reporting Standard only gained traction after Washington enacted FATCA, which compelled other countries to share financial information.
Similarly, even if it has stepped back for now, the United States may later find that joining a global Convention is the best way to protect its companies and ensure predictable, fair tax rules.
📆Timeline
Upcoming
10 Nov 2025 Third session of negotiations in Nairobi
The work plan for the third session prioritises completing the commitments of the Framework Convention by the end of 2025. These are the technical tax provisions that will anchor both the early and future protocols to the Convention.
Anchoring protocols in this way matters because it keeps all future agreements connected to the same core rules and principles. This ensures consistency across the system, prevents gaps or contradictions, and makes international tax cooperation more effective in the long run.
Past
4 Aug 2025 First and second sessions of substantive negotiations in New York
Member States and other stakeholders were invited to share input on the issue notes and overview produced through the intersessional work of the workstreams.
The sessions focused on discussing the commitments included in the Terms of Reference, as well as holding a first scoping discussion on the two early protocols.
The main goal was to gather further feedback that will guide the next phase of intersessional work.
6 Feb 2025 Organisational session adopts rules of procedure and chooses topic for the second early protocol
At the organisational session (3–6 February 2025), the new Intergovernmental Negotiating Committee (INC) selected the prevention and resolution of tax disputes as the subject of the second early protocol. It also agreed that decision-making rules of a two-thirds majority would apply where consensus could not be reached.
The INC’s work is divided into three workstreams: Workstream I focuses on the Framework Convention itself. Workstream II is dedicated to the early protocol on taxation of cross-border services in a digital economy. Workstream III covers the protocol on prevention and resolution of tax disputes.
24 Dec 2024 UN adopts the Terms of Reference for the UN tax convention
The UN General Assembly adopted Resolution 79/235, approving the Terms of Reference and setting the roadmap for drafting the Convention.
Agreed to be negotiated from 2025 to 2027 are the UN Framework Convention on International Tax Cooperation (UNFCITC) and two early protocols, including one on cross-border services.
22 Dec 2023 Ad Hoc Committee created to draft Terms of Reference for the UN tax convention
The UN Secretary-General presented a report on the available options, and the UN General Assembly adopted Resolution 78/230 establishing an Ad Hoc Committee to draft the Terms of Reference for a UN Framework Convention on International Tax Cooperation.
30 Dec 2022 UN adopts a resolution to start talks on a UN tax convention
The Africa Group’s Resolution 77/244 at the UN General Assembly called for intergovernmental discussions on a UN framework for international tax cooperation. It was adopted by consensus, although many OECD members later announced their opposition.
🛠️Resources
Press releases
17 Jun 2025
US ignored as Sevilla ‘financing for development’ outcome is adopted by consensus
16 Jun 2025
Reassert tax sovereignty to unlock trillions for climate finance
3 Jun 2025
Financial secrecy rocks democracies, Financial Secrecy Index finds
4 Feb 2025
US scores own goal on day one of UN tax negotiations
One-page briefings on the ABC’s of Tax Justice & the UN
Automatic exchange of information
Beneficial ownership transparency
Public country by country reporting
Prevention and resolution of tax dispute
Cross-border services
Unitary tax
“The FfD Chronicle” newsletter
The FfD Chronicle newsletter is only updated during active negotiations sessions. When these sessions are underway the newsletter is updated on a daily basis by members of the Civil Society Financing For Development Mechanism who are on the ground at the negotiations. It provides original and invaluable news, insights and perspectives.
You read the newsletter, and subscribe for email updates, here.
UN documents and schedules
See the main webpage for UN negotiations on the UN tax convention
See the Terms of Reference for the UN tax convention
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