The United Nations Framework Convention on International Tax Cooperation is a proposed international legal instrument aimed at improving global tax cooperation.

RF Report

The United Nations has refreshed its webpage on Intergovernmental Negotiations for the UN Framework Convention on International Tax Cooperation, unveiling the Co-Lead’s Draft Framework Convention Template dated 24 October 2025.

The UN Framework Convention on International Tax Cooperation is a proposed international legal instrument aimed at improving global tax cooperation. This Member State-led process will run from 2025 to 2027, with the aim of developing a framework convention that leads to fully inclusive and more effective international tax cooperation.

The update features finalised draft articles covering:

Fair Allocation of Taxing Rights (Article 4)

The States Parties agree that every jurisdiction where a taxpayer conducts business activities, including jurisdictions where value is created, markets are located and revenues are generated, have a right to tax the income generated from such business activities.

High-Net Worth Individuals (Article 5);

  1. In order to prevent high net worth individuals from avoiding or evading taxes, the States Parties agree to adopt measures to detect and thwart such activities, including through expanding the exchange of information to additional types of assets and instruments as such exchange becomes feasible.
  2. The States Parties agree to share information regarding structures and techniques used by high-net worth individuals to avoid and evade taxes and to require appropriate disclosures of such structures and techniques by taxpayers, advisors and intermediaries involved in developing them.
  3. The States Parties agree to adopt coordinated approaches to ensuring effective taxation of high-net worth individuals.

Mutual Administrative Assistance (Article 6)

The States Parties recognise that domestic resource mobilisation depends on the ability of all States to enforce their domestic tax laws. Accordingly, States Parties shall afford one another the widest measure of mutual administrative assistance (including through exchange of information for tax purposes), to support the administration or enforcement of the domestic laws regarding taxes of every kind and description by another State Party. Such administrative assistance will include the exchange of information regarding revenues, expenses, profits, taxes paid, tax planning strategies, tax structuring arrangements, the nature of activities, and any other relevant information.

Illicit Financial Flows, Tax Avoidance and Tax Evasion (Article 7)

The States Parties agree to cooperate in combating tax-related illicit financial flows, including: a) by developing effective tools for the detection of tax-related illicit financial flows, enforced through international cooperation and transparent reporting standards, as necessary to ensure effective taxation of income and profits from tax-related illicit financial flows; and b) through sharing information regarding structures and techniques used by taxpayers to avoid and evade taxes on their income.

Harmful Tax Practices (Article 8)

  1. The States Parties recognise that harmful tax practices undermine the ability of all countries to tax income fairly, particularly income derived by multinational enterprises that can shift assets and income across borders. International cooperation, at global and regional levels, is therefore necessary to address such practices and safeguard equitable taxation.
  2. The States Parties agree that any tax incentives provided by States Parties should be substance-based, linked to investment or performance, and not merely profit-based.
  3. Accordingly, the States Parties agree to cooperate in developing effective tools for combating harmful tax practices, including: a) through sharing information regarding revenues, assets, employees and reported income on a country-by-country basis, taking into account both the needs and the different capacities of the States Parties; and b) by introducing appropriate measures, which may include minimum taxes, on business activities originating from jurisdictions with harmful tax practices.

Sustainable Development (Article 9)

Taking into account their different capacities, the States Parties agree to pursue international tax cooperation approaches that will contribute to the achievement of sustainable development in its three dimensions, economic, social and environmental, in a balanced and integrated manner.

Prevention and Resolution of Tax Disputes (Article 10)

  1. The States Parties recognise that implementation of effective measures for avoiding and resolving tax disputes supports cross-border investment and cross-border trade in goods and services.
  2. The States Parties will seek to minimise the potential for disputes by providing clear and accessible legislation and interpretative guidance regarding tax obligations.
  3. The States Parties will also strive to implement domestic dispute resolution mechanisms that are fair, independent, accessible, and effective in resolving disputes in a timely manner for both taxpayers and the tax authorities involved.

The final draft, comprising 22 articles, will be discussed at the INC’s third session from 10–19 November 2025, with additional sessions in 2026 and 2027. The Framework Convention and two early protocols are planned for submission to the UN General Assembly in September 2027.