Four definitions to change the world: Struggles over meaning in the UN tax convention negotiations

The tax justice movement awaits the publication of the first full draft of the UN Framework Convention on International Tax Cooperation (UNFCITC). It is expected within the coming days.

For those not intimately following the UN intergovernmental negotiations over the last two years, the Report of the High Level Panel on Illicit Financial Flows from Africa strikes at the core of why the status quo in international tax cooperation needs to change:

“The radical reduction of illicit capital outflows from [Africa], short of ending them, is precisely the outcome [Africa] and the rest of the world must achieve to produce this strategically critical new balance…

“As a Panel we are convinced that the goals of ending poverty in the world, reducing inequality within and among nations, and giving practical effect to the fundamental objective of the right of all to development remain vital pillars in the historic process to build a humane, peaceful and prosperous universal human society.”
(Chairperson Thabo Mbeki, p4 of the report)

Ahead of the fifth session of the intergovernmental negotiations to be held in New York, 3-13 August 2026, the draft text will be published in full. Many of the contentious issues are already clear from the previous sessions.

Some of the concepts under discussion are not yet clearly defined, and remain abstract yet are foundational for the successful implementation and operationalisation of the Convention’s principles and commitments. To help shed some light, in advance of the opportunity to comment upon and influence full draft text for the Convention and the two early Protocols, we wanted to support a nuanced understanding and discussion of these concepts. In a series of four webinars we brought together researchers, governmental negotiators and advocates to unpick some of the complexity and the implications. 

To agree a common understanding of such issues opens up the space to create a high reaching and legitimate UN tax convention. This is surely what we need to change our world and to flourish!

You can find recordings of the first four webinars below. We plan to delve into to other topics later in the year.

Watch the webinar recordings

Harmful Tax Practices – defining potentially unacceptable State behaviours.

Foreseeable Relevance – as a limiting criterion for the exchange of information between states.

Value Creation – as a potentially problematic basis for determining the location of companies’ real activity.

Illicit Financial Flows – an agreed component of the negotiations, with a formal UN statistical definition and potentially wide implications.

Background resources can be found here on our dedicated UN tax convention page