Between 3 August and 13 August, the Intergovernmental Negotiating Committee of the United Nations Framework Convention on International Tax Cooperation (UNFCITC) met in New York for the fifth session of negotiations.
The fifth session marked the half-way point of the three year negotiation term. The Intergovernmental Negotiation Committee is expected to complete its work and submit the final text of the framework convention and the two early protocols to the General Assembly of the United Nations by the end of 2027.
The fifth session also marked the first session of negotiations in which delegates discussed ‘zero-drafts’ with a full text on both the framework convention and its protocols.
At the Tax Justice Network, we follow the negotiations of this potentially world-changing treaty closely. A full extended summary by our staff of the fifth session of negotiations is available here.
After the session, interested stakeholders were invited to submit comments on the so-called ‘zero-drafts’ and the negotiations in New York. The ‘zero-draft’ for each workstream is provided below, along with links to the Tax Justice Network’s written stakeholder input on each.
Workstream 1- Framework Convention:
Workstream 2 – Protocol on Cross-Border Services:
Workstream 3 – Protocol on Dispute Prevention and Resolution:
More information on the UN tax frame convention can be found on our dedicated webpage. The webpage includes, among other things, latest news on the negotiations, a build-a-convention tracker with summaries and analysis on the various components of the convention, a country position database and technical notes on the negotiations, including notes on the recent draft services protocol and notes on the dispute protocol.
The Sixth Session of negotiations takes place in Nairobi between 30 November and 10 December 2026.
Related articles
Notes on the UN tax convention draft protocol on dispute prevention and resolution
11 September 2026
Report of the Fifth Session of negotiations on the UN tax convention
4 September 2026
Submission to Workstream I on Co-Lead’s Zero Draft of UN Framework Convention on International Tax Cooperation (post-Fifth Session)
28 August 2026
Submission to Workstream II on Taxation of Income from Cross-Border Services (post-Fifth Session)
26 August 2026
Submission to Workstream III on Dispute Prevention and Resolution (post-Fifth Session)
24 August 2026

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