Highlights and images for 10 November 2025

The ability of states to collect taxes is a fundamental aspect of sovereignty. As such, tax cooperation goes back a long way in the history of modern multilateralism, all the way back to the League of Nations. Then, as now, the underlying questions were similar: what is fairness in determining the right to tax; how can governments gain an appropriate share of taxation revenue from multinational corporations without discouraging the desired level of foreign investment; and how can taxpayers be protected from double taxation.

Recent developments have brought these questions under renewed scrutiny. One is the rise of large e-commerce platforms and the digital services that operate across borders without having a bricks-and-mortar presence in their market countries. Another is the sharp decline in traditional sources of development financing for countries of the Global South. More than one delegate on Monday noted that the outcome of the 4th International Conference on Financing for Development in Seville, Spain, included a commitment to boosting domestic resource mobilization—a commitment that will likely necessitate tax policy reforms.   

These issues were front and center at the opening of the Third Intergovernmental Negotiating Committee on the UN Framework Convention on International Tax Cooperation (INC-3) negotiations. Chair Ramy Youssef, Egypt’s Deputy Minister of Finance for Tax Policy and Reforms, briefed delegates on progress made since INC-1 and INC-2 in August. Shari Spiegel, UN Department for Economic and Social Affairs (DESA), stressed that the Sevilla Commitment on Financing for Development had encouraged support for the INC process. Youssef and Spiegel both welcomed the larger number of stakeholders participating in INC-3. 

Chair Youssef introduced the programme of work (A/AC.298/CRP.20), and the draft decision on the participation of international organizations, civil society and other relevant stakeholders (A/AC.298/CRP.19). Delegates adopted the decision. Youssef then convened an informal meeting and Co-Lead Daniel Atwere Nuer (Ghana) introduced the Draft Framework Convention Template of 24 October 2025.

In plenary, delegates reviewed the proposed text of Article 4 of the draft Framework Convention concerning the fair allocation of taxing rights. Member States debated which factors should count in allocating taxing rights. They expressed concerns about the relationship between the proposed framework convention and its protocols, and other multilateral and bilateral arrangements.

They also delved into the meaning of “value creation”, “market location” and “revenue generation” as providing the basis for taxation. Some proposed adding “residence” as another criteria determining whether taxation rights should apply; others warned against definitions that rely on physical presence in a given location.  

Many civil society and international organizations also made statements calling for confronting historical inequalities, ensuring fairness for taxpayers, and ensuring that tax policies do not shift burdens to those least able to bear them. 

In the afternoon, delegates took up discussion of Article 5 on High Net-Worth Individuals (HNWIs), which addresses ways to prevent tax avoidance and evasion. Article 5 also provides for States Parties to share information regarding common structures and techniques of avoidance. Some Member States stressed that taxation of individuals is a matter for domestic regulation, and others suggested having a concrete definition of HNWIs. Many delegates preferred to address information exchange on wealth taxation across borders, rather than refer specifically to HNWIs.

Discussions will continue on Tuesday.