Discussions during the third of nine negotiating sessions planned to advance the talks towards an international tax cooperation treaty focused on the text of the future framework convention – and protocols on taxation of income derived from the provision of cross-border services in an increasingly digitalized and globalized economy, and on prevention and resolution of tax disputes.
The Earth Negotiations Bulletin (ENB) summary report of the meeting notes that the third session of the Intergovernmental Negotiating Committee (INC) on the UN Framework Convention on International Tax Cooperation convened amid the increasingly urgent need for new ways to fund the global development agenda. With official development assistance (ODA) dropping 33% in 2025, the outcome document of the Fourth International Conference on Financing for Development (FfD4) underscored the need to increase domestic resource mobilization, including by tightening global tax practices, – and the INC aims “to do just that.”
According to ENB, key questions that emerged during discussions on the commitments members intend to make in the future framework convention relate to, inter alia:
- Fairness in determining the right to tax;
- How governments can gain an appropriate share of taxation revenue from multinational enterprises without discouraging the desired level of foreign investment; and
- How taxpayers can be protected from double taxation.
Initial discussions took place on illicit financial flows, tax evasion, and tax avoidance, as well as on taxing high-net-worth individuals, among other issues. The INC also opened discussions on capacity building and technical assistance, with many delegates calling for country-driven needs assessments.
Technical discussions on issues related to the prevention and resolution of tax disputes “addressed matters such as the efficacy of advance pricing agreements, how best to enhance mutual agreement procedures, and if and how to mandate mandatory arbitration procedures,” ENB reports. Delegates “also considered the role of the UN in bridging the information gap, which is crucial to decision making in tax matters.”
“As the international community moves forward with negotiations on the Framework Convention and its Protocols,” the ENB analysis of the meeting notes, the INC Chair “praised delegates for working in a spirit of inclusivity and participation, with all countries operating ‘on equal footing.’” The US does not participate in these negotiations.
Intersessional work will continue in advance of the INC’s next meeting in February 2026. INC-3 convened in Nairobi, Kenya, from 10-19 November 2025. It brought together over 120 representatives of governments, industry, and civil society. [ENB Coverage of INC-3]