The UN Committee of Experts on International Cooperation in Tax Matters held its 31st session from 21 to 24 October 2025. This was the first meeting of the new membership of 25 tax experts appointed for a four-year term from 2025 to 2029. The new subcommittees and workstreams were discussed at the meeting.
UN Model Tax Convention
Work on the UN Model Tax Convention is central to the role of the Tax Committee, and this work will be continued by a subcommittee appointed for the next four years. The members will review the work done previously on the Convention and monitor the extent to which new provisions in the UN Model are being taken up in practice by developing countries in their bilateral tax treaties. New additions and amendments to the UN Model will be discussed where these are considered necessary.
Transfer Pricing issues
Transfer pricing is an important issue for developing countries. The new subcommittee will review the UN Practical Manual on Transfer Pricing, considering the needs of developing countries. Strengthening of transfer pricing capacity is important for developing countries, to boost domestic resource mobilisation. The subcommittee will aim to produce more sector-specific guidance on transfer pricing issues.
Extractive Industries taxation
The Committee favoured the creation of a subcommittee on the extractive industries. Developing countries could benefit from further guidance on the valuation of minerals for tax purposes; and the subcommittee could also continue to monitor issues around the energy transition in developing countries, liaising with other relevant subcommittees. The subcommittee could distinctive characteristics of the market for critical minerals including the lack of proven international market pricing; the need for local processing to increase value; and the need for an efficient audit system.
Environmental taxation
The Committee also considered that it was important to do more work on taxation and the environment, helping developing countries to improve the design of their tax systems to protect the environment and to increase domestic resource mobilisation. The work would look at issues such as fuel taxes, carbon taxes and incentives for new green technologies. This would require coordination with the subcommittee on extractives taxation on some issues.
Tax Administration and AI
Members of the Tax Committee considered that there was a role for the Committee in providing practical guidance for developing countries, especially the less developed countries that would be faced by significant budgetary issues in introducing AI systems. AI could be used by a tax administration to assist the tax policy decision-making process and could help in detection of tax fraud; risk assessment; and taxpayer services. There would need to be safeguards against AI-facilitated tax avoidance and evasion. The focus of the subcommittee would be on practical implementation of AI systems.
Other Issues
Work on VAT/GST issues could include topics such as VAT in the construction industry; interaction between VAT and other taxes; and VAT in relation to government entities and charities. Other issues could include VAT issues for digital platforms, and cross-border VAT disputes. Output from the discussions could be included in a Handbook on VAT/GST or issued as guidance papers on the relevant topics.
Other important issues to be considered by the Tax Committee in the next four years will include the taxation of high-net-worth individuals (HNWIs); and issues around tax, gender and the informal sector. The members were favourable to setting up a subcommittee to consider these issues.
