The world of business is increasingly globalized and digitalized. Companies in one country may employ labor in another country and serve consumers in yet another. Which governments, then, should collect the tax—and who decides that? For tax purposes, how should companies with no physical presence be treated vis-à-vis those with a bricks-and-mortar presence? How can fairness and efficiency be promoted, and double taxation avoided?

Negotiations toward this new, UN-led convention seek to answer such questions. The negotiations are a critical step in the fight for tax justice, as it will create a more equitable decision-making forum for all countries, including those that have traditionally been excluded from decision making. The convention and its protocols are expected to tackle issues including tax base erosion, profit shifting, and tax evasion, which prevent developing countries, in particular, from mobilizing domestic revenue that is crucial for their sustainable development.

The Programme of Work for the third session of the Intergovernmental Negotiating Committee to develop a UN Framework Convention on International Tax Cooperation (INC3) included discussion of proposals for a draft structure for the framework convention and two protocols: Protocol 1 on taxation of income derived from the provision of cross-border services in an increasingly digitalized and globalized economy, and Protocol 2 on prevention and resolution of tax disputes.

During its organizational session in New York from 3-6 February 2025, delegates agreed on decision-making rules for the negotiation process. At the INC’s first and second sessions in August 2025, delegates discussed cross-border services, including definitions of “services,” and processes for dispute prevention and resolution, including ways to ensure that tax authorities have the necessary information for resolving issues. The negotiations were expected to have at least three substantive sessions per year, with final texts to be submitted in 2027 during the General Assembly’s 82nd session.

INC-3 took place from 10–19 November 2025, in Nairobi, Kenya.

The Earth Negotiations Bulletin (ENB) writers for this meeting were Delia Paul, Ph.D.; Tallash Kantai; and Gabriella Boger Prado. The Digital Editor was Danny Skilton. The Editor was Pam Chasek, Ph.D.