UN: 32nd Session of Committee of Experts on Tax Cooperation

The 32nd session of the UN Committee of Experts on International Cooperation in Tax Matters is to be held from 23 to 26 March 2026. A provisional agenda has been issued, which includes the following topics:

UN Model Tax Convention

Work on the UN Model Tax Convention is central to the role of the Tax Committee. The Committee will need to 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 also be the subject of discussions. The Committee will be considering an update of the United Nations Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries.

Transfer Pricing

The UN Practical Manual on Transfer Pricing will be reviewed and where necessary expanded, in line with the needs of developing countries. Strengthening of transfer pricing capacity is important for improving domestic resource mobilisation to enable developing countries to achieve the sustainable development goals. There may be more sector-specific guidance on transfer pricing issues.

Tax Administration and AI

The use of AI could assist a tax administration in the tax policy decision-making process. The AI could help to detect tax fraud; carry out risk assessment; and improve taxpayer services. The tax administration would need safeguards against AI-facilitated tax avoidance and evasion. There would also need to be guardrails around AI to protect taxpayer confidentiality and data security. The tax committee may focus on producing guidance on the practical implementation of AI systems.

Extractive industries taxation

Developing countries could benefit from further guidance on the valuation of minerals for tax purposes; and could also continue to monitor issues around the energy transition in developing countries. Guidance could be produced on issues concerning the market for critical minerals such as the lack of proven international market pricing; the need for local processing to increase value; and the need for an efficient audit system. An additional chapter could be added to the Handbook to cover negotiations on critical minerals issues.

Indirect tax issues

The Tax Committee is continuing to consider work on VAT/GST issues. This 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 that could be included in discussions are VAT issues for digital platforms and cross-border VAT disputes. The output could be included in a Handbook on VAT/GST or issued as guidance papers on the relevant topics.

Environmental taxation

The Committee aims to help developing countries in improving the design of their tax systems to protect the environment and to increase domestic resource mobilisation. The work may look at issues such as fuel taxes, carbon taxes and incentives for new green technologies.

Wealth taxation

The taxation of high-net-worth individuals (HNWIs) is seen as important for progress in domestic resource mobilisation. This could be implemented through a wealth tax or possibly a minimum level of income tax on wealthy individuals calculated by reference to net wealth. To be effective, the taxation of HNWIs requires international cooperation, and this aspect can be considered by the Committee.

Tax and gender

Another issue on which the Committee is keen to make progress is the issue of tax, gender and the informal sector. This will involve work on the position of women in the tax system and will also look at the treatment of businesses in the informal sector, many of which are run by women.

Capacity building

The need for capacity building has been in the spotlight as the Intergovernmental Negotiating Committee discussing the UN Framework Convention on Tax Cooperation has referred to the importance of supporting countries with the implementation of the Convention when it is finalised. The Tax Committee will look at the need for more capacity building by the UN in cooperation with other international and regional organisations.