Negotiation of a new treaty on taxation is now underway, as an intergovernmental negotiating committee (INC) has begun developing a framework convention designed to achieve fully inclusive and effective international tax cooperation.

This new convention is expected to reform the architecture of the international financial system and is viewed by many developing countries as a critical step in the fight for tax justice. While current tax law has been shaped primarily by the Organisation for Economic Co-Operation and Development (OECD) and the G20, many believe a UN convention will be more inclusive and give an equal say to countries that have been previously been excluded from decision-making. Proponents believe this new treaty will facilitate more equitable taxation of multinational corporations, significantly reduce the ability of the world’s wealthiest to avoid taxation, and facilitate cooperation to address environmental and sustainable development challenges.

The UN General Assembly adopted resolution 79/235, which established the INC and its terms of reference on 24 December 2024. Negotiations of the new treaty will be held between 2025 and 2027, with at least three substantive sessions per year of up to ten working days each. The INC will aim to submit a final text in the first quarter of the UN General Assembly’s 82nd session in late 2027.

The INC is charged with drafting the Convention and two early protocols. UN Member States have agreed that the first protocol will address taxation of income derived from provision of cross-border services in an increasingly digitalized and globalized economy. The subject of the second will be decided based on a list of priority areas set out in the Terms of Reference, including: taxation of the digitalized economy; measures against tax-related illicit financial flows; prevention and resolution of tax disputes; and addressing tax evasion and avoidance by high-net worth individuals and ensuring their effective taxation in relevant Member States.

In addition to deciding on the subject of the second early protocol, the organizational session of the INC addressed organizational matters, including election of a bureau and its decision-making rules.

The Organizational Session convened at UN Headquarters in New York from 3-6 February 2025.

The Earth Negotiations Bulletin (ENB) writers for this meeting were Jessica Templeton, Ph.D.; Hillary Rosentreter; and Lynn Wagner, Ph.D. The Digital Editor was Matthew TenBruggencate. The Editor was Pam Chasek, Ph.D.