Meeting for the first time under its new membership, the UN Committee of Experts on International Cooperation in Tax Matters has outlined a broad work programme for 2025–2029. Priorities include updates to the UN Model Tax Convention, renewed guidance on transfer pricing and extractive industries, and new subcommittees on AI in tax administration, environmental taxation, and gender and informality in tax systems.
The 31st session of the UN Committee of Experts on International Cooperation in Tax Matters was held In Geneva from 21 to 24 October 2025. This was the first meeting of the newly-appointed membership of the Committee, consisting of 25 tax experts who have been appointed for a four-year term from 2025 to 2029.
The Committee discussed issues concerning updates to the UN Model Tax Convention; transfer pricing issues affecting developing countries; taxation of the extractives industry; tax issues around the energy transition; and other taxes that can achieve progress in domestic revenue mobilisation.
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 treaty 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 also be discussed where these are considered necessary.
There will again be a subcommittee on transfer pricing, an issue that is important for developing countries. 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 (SDGs). The subcommittee will also aim to produce more sector-specific guidance on transfer pricing issues.
The Committee also favoured the creation of a subcommittee on the extractive industries. The Committee has previously done significant work on the UN Handbook on Selected Issues for Taxation of 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 on extractives industries would bring together a multidisciplinary group including outside experts.
Members of the Tax Committee were in favour of creating a subcommittee on tax administration and AI. They 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 taking the decision to use AI.
A tax administration could use AI to assist the tax policy decision-making process and help in detecting tax fraud; conducting risk assessment; and improving taxpayer services. The Committee noted that countries would need safeguards around taxpayer confidentiality. The focus would be on guidance on practical implementation of AI systems. The subcommittee could bring in multi-disciplinary expertise from tax administrators, regional representatives, lawyers and others to ensure practical input for the final guidance.
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.
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), which is seen as important for progress in domestic resource mobilisation.
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. The members were favourable to setting up subcommittees to consider these issues.
