The Intergovernmental Negotiating Committee on the UN Framework Convention on International Tax Cooperation has released a Roadmap and working methods on 4 April 2025 for developing the Framework Convention and two initial protocols.
It outlines three workstreams to be completed by July 2027.
Roadmap and working methods
Introduction
The INC is charged with developing the UN Framework Convention on International Tax Cooperation in accordance with the Terms of Reference (ToR), as well as two early simultaneous protocols, one on the “taxation of income derived from the provision of cross-border services in an increasingly digitalized and globalized economy” and one on the “prevention and resolution of tax disputes.
The text of the draft Framework Convention and the two early protocols will be submitted to the UN General Assembly for its consideration in the first quarter of its 82nd session in the second half of 2027. The “framework protocol approach” and the ToR provide the basis for the INC’s work plan. The INC will meet for three sessions each year in 2025, 2026 and 2027; any formal decisions will be taken at those sessions of the INC Plenary.
This document provides further information in this regard and was prepared by the Chair, in coordination with the INC Bureau. The development of the three legal instruments (the framework convention and two early protocols) will be organized into three workstreams, one for each legal instrument.
The substantive work of each workstream and the roadmap setting out approximate timelines will correspond to the nature of the instruments to be developed, the available meeting dates and venues for the three Committee sessions per year; and the ambitions for inclusive and effective international tax cooperation expressed by Member States in resolutions 77/244, 78/230 and 79/235 and the ToR adopted by the General Assembly. In mandating the INC, the General Assembly also encouraged international organizations, civil society and other relevant stakeholders to contribute to the work of the intergovernmental negotiating committee in accordance with established practices.
General approach and overview
The informal intersessional work will be divided into three workstreams, corresponding to each legal instrument to be developed. Two Co-Leads will guide the work under each workstream, which will consist of developing draft texts and proposals during informal consultations ahead of consideration of such proposals during formal meetings.
The two Co-Leads of each workstream will be responsible for developing a work plan for the workstream/legal instrument, including identifying the necessary work, the order in which work will be undertaken, important milestones and deadlines for achieving each milestone, in light of the nature, scope and mechanics of each legal instrument.
If deemed necessary, additional informal taskforces can be formed as part of the workstreams to focus on defined aspects, provisions, or components of the respective legal instrument.
This overall arrangement of the workstreams should allow for a targeted and effective, yet flexible and inclusive, process of developing the three different instruments within the timeframe available.
Workstream I: Framework Convention
Workstream I will be responsible for developing proposals in respect of the framework convention. The work of this workstream will be informed by the nature of the “framework protocol approach” and specifically the ToR outlining the structure and future content of the framework convention. As such, there is a clear starting point for the substantive work on the instrument.
Workstream II: Protocol 1 – Taxation of services
Workstream II will be responsible for developing proposals in respect of the protocol on the taxation of income derived from the provision of cross-border services in an increasingly digitalized and globalized economy. Substantive work on this workstream will require an initial scoping exercise to develop proposal(s) on the coverage of the protocol.
Workstream III: Protocol 2 – Dispute prevention and resolution
Workstream III will be responsible for developing proposals in respect of the protocol on prevention and resolution of tax disputes. Substantive work on this workstream will require an initial scoping exercise to develop proposal(s) on the coverage of the protocol.
