The UN Committee of Experts opened its 31st session in Geneva on 21 October 2025 to discuss updates to the Model Tax Convention, revise the treaty negotiation manual, and address extractive industry taxation, forming subcommittees for the first two topics while deferring decisions on the third.

The UN Committee of Experts on International Cooperation in Tax Matters opened its 31st session in Geneva on 21 October 2025, initiating discussions on updates to the UN Model Tax Convention, revisions to the bilateral treaty negotiation manual, and extractive industry taxation, while forming subcommittees to advance the first two areas and postponing decisions on the latter.

The Committee’s first two meetings focused on key tax-related topics, using specific Conference Room Papers (CRPs) as guidance. Discussions included the United Nations Model Tax Convention, informed by CRP 22, and the potential revision of the United Nations Manual for negotiating bilateral tax treaties between developed and developing nations, guided by CRP 23. Additionally, the Committee explored other areas within its work programme, such as taxation in the extractive industries, with insights drawn from CRP 27. These discussions aimed to provide direction and updates on critical international tax matters.

Summary of Conference Room Paper 22 (CRP 22) – Proposed workstream for the work on the UN Model Tax Convention

This note outlines options for the proposed workstream.

The Economic and Social Council’s mandate to the Committee of Experts requires it to “keep under review and update as necessary” the United Nations Model Tax Convention (the UN Model). The Committee approved a substantial update to the UN Model at its Thirtieth Session. However, the last membership of the Committee identified a number of issues relating to the UN Model that remain outstanding. It recommended that this membership of the Committee should consider working on those issues.

This note summarises issues raised by the previous Committee membership, Member States, and other stakeholders and requests Members to identify any additional issues. The Committee is further asked to decide whether to establish a subcommittee to undertake this work and to provide guidance on priorities among the various issues.

The Committee’s primary task is to prioritise which UN Model issues to address during its term. The Committee is further asked to decide whether to establish a subcommittee to undertake this work and to provide guidance on priorities among the various issues.

Summary of Conference Room Paper 23 (CRP 23) – Proposed workstream for the work on the UN Manual for the Negotiation of Bilateral

Tax Treaties

This note outlines options for the proposed workstream.

The Economic and Social Council’s mandate to the Committee of Experts requires it to “keep under review and update as necessary” the Manual for the Negotiation of Bilateral Tax Treaties between Developed and Developing Countries (the Manual). The Committee approved the current Manual in 2023, reflecting the 2021 UN Model. The Committee’s primary task is to decide whether to update the Manual during this membership term and, if so, what scope the update should take.

This note summarises issues raised by the previous Committee membership, Member States, and other stakeholders, and it presents two options for consideration. The Committee is further asked to decide whether to establish a subcommittee to undertake this work and to provide guidance on priorities among the various issues.

Summary of Conference Room Paper 27 (CRP 27) – Secretariat Note on Extractive Industries Taxation

This note is provided to the Committee for information and discussion at its Thirty-first Session.

The Committee has produced comprehensive guidance on extractive industries taxation through the 2017 Handbook, 2021 second edition, and 2025 Supplement.

This body of guidance has strengthened developing countries’ ability to mobilise revenue from extractives and adapt fiscal regimes to emerging challenges and sustainable development goals. A gap remains for practical guidance on valuing critical minerals, where the dynamics of energy transition create distinctive challenges, including rapid price volatility, limited comparable data for specialised battery-grade materials, and evolving market/marketing chains. This paper presents a potential output—supplementary guidance on critical minerals valuation—and a standing activity to monitor developments in energy transition taxation and identify any emerging gaps.

Three options are presented:

(A) monitoring only;

(B) guidance and monitoring; or

(C) no action/ no establishment of a workstream on extractives industries taxation.

Questions for Committee:

i.) Should the Committee establish this workstream?

ii.) Which option does it prefer?

iii.) Should a Subcommittee be established, and what guidance on its composition should be provided?