In March 2025, the UN Tax Committee finalised its 2025 update of the UN Model Tax Convention, a key template for bilateral tax treaties, particularly used by Global South countries. This report by the Tax Justice Network analyses the significant changes introduced in the update. The revisions aim to strengthen and expand source countries’ taxing rights on income from various services, including extractive industries, international shipping, software, and insurance premiums, while also introducing a subject-to-tax rule and new dispute resolution provisions.
The 2025 update removes the UN Model’s previous tagline of being for treaties “between developed and developing countries,” positioning it instead as an inclusive model relevant to all UN Member States. These changes signal a shift towards fairer and more equitable global tax rules, reflecting the Committee’s ongoing mandate to prioritise Global South interests. As negotiations advance towards a UN Framework Convention on International Tax Cooperation, this updated UN Model serves as a crucial indicator of where international tax policy debates are heading and provides practical groundwork for future protocols on cross-border services and dispute resolution.