The UN Tax Committee reviewed proposals to establish new workstreams on extractive industries, digital economy, and transfer pricing—aiming to enhance guidance on critical minerals valuation, digital services and remote work taxation, and transfer pricing practices to better support developing countries’ revenue mobilisation and policy implementation during the 2025–2029 term.

On the second day of its 31st session, the UN Committee of Experts on International Cooperation in Tax Matters approved the creation of three new subcommittees focused on the taxation of extractive industries (CRP.27), the digitalized and globalized economy (CRP.24), and transfer pricing (CRP.29). These decisions followed in-depth discussions on the proposed objectives and priorities for each area, with members highlighting the need for strong coordination among workstreams and adaptability to evolving global tax issues.

As previously reported, 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 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 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 creates 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?

Summary of Conference Room Paper 24 (CRP 24) – Secretariat Note on Taxation of the Digitalised and Globalised Economy

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

The UN Tax Committee has made substantial changes to the UN Model Tax Convention in recent years, addressing taxation of services in a digitalised and globalised economy, including new Article 12AA (consolidating services taxation) and Article 12B (automated digital services).

The previous Committee Membership identified that practical implementation guidance remained incomplete on such work, and that work on remote workers remains unfinished. Stakeholder submissions demonstrate sustained interest in services taxation, with proposals ranging from implementation guidance for recently adopted provisions to suggestions for additional Model changes. The need for greater guidance on remote working was also raised as a persistent issue.

The Committee’s primary task is to prioritise among these issues based on developing country demand, urgency for domestic resource mobilisation and sustainable development efforts, readiness for resolution during the 2025-2029 term, availability of expertise, and linkages with other Committee work. This note presents two potential outputs for consideration:

Questions for Committee consideration:

  1. a) Which outputs to pursue during the 2025-2029 term: Output A only (an initial evaluation report (by the Thirty-third Session, October 2026) assessing whether 2025 UN Model provisions adequately address services permanent establishments, emerging technologies (including artificial intelligence), and remote working arrangements. – possibly to be followed by further action); Output B only (Practical implementation guidance on taxation of services (for completion by the Thirty-sixth Session, March 2028) covering treaty negotiation, domestic law implementation, and administrative aspects); both outputs, or neither output;
  2. b) What are the priorities for Committee guidance within selected outputs, recognizing that the Committee cannot address all issues raised by stakeholders in this Membership; and c) Whether to establish a Subcommittee to undertake the work and provide guidance on its composition.

Summary of Conference Room Paper 24 (CRP 24) – Other areas for Committee consideration and guidance as part of its work program Secretariat Note on Transfer Pricing

This note presents three potential transfer pricing outputs for Committee consideration: (A) update the United Nations Practical Manual on Transfer Pricing for Developing Countries, focusing on intragroup financial transactions, intangibles, intragroup services, and simplification measures including safe harbors; (B) develop guidance on arm’s length attribution of profits to permanent establishments; and (C) produce industry/sector-specific guidance for industries prone to abusive transfer pricing (e.g., telecommunications and tourism). The note provides information to assist the Committee in prioritising among these possible outputs based on developing country demand, urgency for domestic resource mobilisation and sustainable development efforts, readiness for resolution during the 2025-2029 Committee term, and availability of expertise and linkages with other workstreams.

The 2021-2025 Subcommittee on Transfer Pricing identified gaps in certain chapters of the 2021 UN Practical Manual on Transfer Pricing for Developing Countries. Stakeholder submissions echoed some of these priorities, with three submissions requesting guidance on simplification, including safe harbors, and several noting the importance of attribution of profits to permanent establishments.

If the Committee pursues all three outputs, it is estimated that the Manual update would require three to three and a half years. Guidance on permanent establishment profit attribution would be linked to the work schedule of any UN Model Subcommittee, with work spanning 2026 to 2029. Industry/sector-specific guidance could be produced throughout the membership term. The outputs can be pursued individually or in combination, depending on the Committee’s priorities.

Questions for Committee consideration:

Should the Committee undertake transfer pricing work this term?

Should the Committee pursue all three proposed outputs, focus on a smaller number of priorities, or sequence the work?

Should a multi-stakeholder Subcommittee on Transfer Pricing be established?