The Global Alliance for Tax Justice in the first and second sessions of the negotiations for a UN Framework Convention on International Tax Cooperation.
August 4 – 15, 2025
Civil society has been a driving force to establish a UN Framework Convention on International Tax Cooperation (UN Tax Convention). Highlighting the hundreds of billions of dollars lost annually from tax abuse by the rich and multinational corporations, the Global Alliance for Tax Justice (GATJ) has called this rampant tax abuse a failure of the current global tax rules. These rules were formulated without the participation of Global South countries and have resulted in an unfair allocation of taxing rights. It is against this backdrop that, for over a decade, GATJ has pushed to fix this system through a global tax body at the UN.
The historic process to fix the global tax rules has now begun. Following years of work by negotiators with inputs from civil society, the adoption of the Terms of Reference of the UN Tax Convention by the UN General Assembly in 2024 officially launched the process. Negotiations for the legally-binding UN Tax Convention and two early protocols run until mid-2027.
From August 4 to 15, 2025, UN Member States met at the UN Headquarters in New York for the start of the substantive negotiations for the UN Tax Convention and two early protocols. Civil Society and other stakeholders actively participated in the negotiations. These first two sessions began conversations exploring the content and structure of the convention and protocols. Throughout the first and second sessions, civil society has continued to play a crucial role, calling for keeping high ambition to deliver tax justice.
Civil Society United for a UN Tax Convention
As a South-led global coalition uniting the tax justice movement, GATJ convenes civil society to push for a robust and ambitious UN Tax Convention. The GATJ Secretariat and regional member networks from Tax Justice Network Africa (TJNA), Tax Justice Europe (TJ-E), Red de Justicia Fiscal de América Latina y el Caribe (RJFALC), and Tax and Fiscal Justice Asia (TAFJA) took part in the negotiations. GATJ represents over 100 organisations with diverse thematic and regional expertise, resulting in meaningful contributions to the negotiation process.
Civil society came to New York prepared, with clear demands and over 50 civil society experts from tax to intersecting movements on gender, development, human rights, and climate justice. Co-coordinating the UN Tax Convention Working Group with its member Eurodad, GATJ convened civil society to act as a cohesive voice through submissions, newsletters, events, and interventions. Ahead of the negotiations, GATJ made three submissions on the negotiations, each signed by 100+ civil society organisations and trade unions. At the start of each week of negotiations, GATJ held a civil society and trade unions workshop to inform, strategise and organise for the week ahead in addition to holding daily coordination meetings during the negotiations.
GATJ facilitated important spaces for civil society to contribute to these discussions from both inside and outside of the negotiating room. GATJ and the Civil Society Financing for Development Mechanism organised side events where civil society presented joint positions to a diverse attendance of negotiators and other stakeholders. Throughout the sessions, civil society produced an FfD Chronicle. As the negotiations began and progressed over the two weeks, issues spanned a diverse range of topics from sustainable development to the transfer pricing system. The Chronicle served as a tool to inform negotiators of civil society positions, but also to provide those from tax backgrounds with insights into established UN practices and the linkages of taxation with existing UN agreements on development, climate, gender, human rights, and global governance.
GATJ provided the following interventions in the negotiations and side events, highlighting key issues at stake in the UN Tax Convention.
The Urgency of International Tax Cooperation
At the start of the negotiations, Ryad Selmani, Tax Justice Officer at CCFD-Terre Solidaire, a member of Tax Justice Europe, intervened on the significance of the moment: “This is not about writing a simple body of non-binding technical rules, optional mechanisms, weak principles, and commitments that can be revoked at any time. It is about establishing a fair, inclusive, transparent, and equitable international tax system that truly contributes to sustainable development, effectively combats abuses, and finally gives every country an equal voice… It is not tax cooperation that threatens state sovereignty, but tax abuse and injustice. And this injustice is made possible because a small group of countries is able to impose abusive tax practices that compromise the ability of all others, both in the North and the South, to collect taxes effectively. This is not a time for uncertainty nor hesitation. The situation is urgent, and the stakes are far too high: for counties to finance public services, education, health, development, and the fight against climate change.”
Throughout the two weeks of negotiations, civil society as well as Member States continued to highlight the importance of these negotiations and the task at hand. In the civil society-led side event, Tove Maria Ryding, Tax Justice Manager at Eurodad and Coordinating Committee Member of GATJ intervened:
“Delivering a strong framework convention is in the interest of all. The present international tax system with thousands of bilateral tax treaties is incoherent, failing countries in both the Global South and North. Now, countries must produce a robust framework convention that gives a strong mandate to the future Conference of the Parties to continue developing this crucial work.”
The current global tax rules were developed at a time when many countries did not have political independence and past attempts at solutions have continued to exclude Global South from the conversation. Everlyn Muendo, Senior Tax Policy Lead at Tax Justice Network Africa, a regional member network of GATJ, shared: “We are here to rectify a historical wrong where taxing rights have been imbalanced affecting Africa and other Global South countries.”
Civil society repeatedly shared the importance of these negotiations to fix flawed rules that do not work in the Global South, nor the Global North. Dr. Dereje Alemayehu, Executive Coordinator of GATJ, explained:
“The choice before us is simple: either we recycle the same failed OECD frameworks, or we have the courage to build something new, a truly universal, democratic UN Tax Convention that serves all countries, especially those who have been historically excluded from decision-making on tax.”
Moving Beyond Transfer Pricing: The Need for Unitary Taxation with Formulary Apportionment
The negotiations follow three workstreams: Workstream I on the framework convention; Workstream II on the first early protocol, taxation of income derived from the provision of cross-border services in an increasingly digitalized and globalized economy; and Workstream III on the second early protocol, prevention and resolution of tax disputes. Across all three workstreams, civil society highlighted that the transfer pricing system prevents countries from effectively taxing multinational corporations where real economic activity takes place.
Assessing the barriers to preventing and resolving tax disputes, Lison Rehbinder, GATJ Global Campaigns and Policy Advocacy Coordinator – Europe, intervened: “We would like to highlight the need to address the root of the problem: the current corporate tax system based on transfer pricing rules and the arm’s length principle. This system is unfit for purpose. It prevents countries from taxing corporate income effectively and it generates countless disputes that are costly and time-consuming to resolve.”
This sentiment was repeated across multiple interventions, with Luis Moreno, Chair of GATJ and member of Red de Justicia Fiscal de America Latina y el Caribe, stating: “The transfer pricing system reflect one of the greatest fictions of the 20th century, namely that a multinational and its subsidiaries are independent entities. This is perhaps the most costly fiction in modern history… Multinational corporations should be treated as a single entity and taxed on the basis of their worldwide profits, distributed fairly among countries according to their real economic activity. In other words, it is time to move to unitary taxation with formulary apportionment.”
An International Tax System for Sustainable Development
The Terms of Reference gives the mandate for the UN Tax Convention to establish a framework convention for sustainable development in all three areas: social, economic, and environmental. Maureen Mburu, GATJ Tax and Gender Lead & Africa Campaigns Coordinator, intervened on the importance of linking taxation to sustainable development: “The revenue losses from the current system erode the capacity of governments to fund essential public services, from health to education, that are essential for gender equality and the achievement of the Sustainable Development Goals.”
Civil society also emphasized the importance of including agreed-upon language from other UN processes, notably the 4th International Conference on Financing for Development which took place the month before the August UN Tax Convention negotiations. Adrián Falco, Coordinator of Red de Justicia Fiscal de América Latina y el Caribe, highlighted key language that was adopted: “This Convention should include specific mentions of the goal of reducing inequality within and between countries, environmental protection, gender equality, and the promotion of progressive tax systems.”
On the importance of addressing taxation from a political lens, Jeannie Manipon, Co-Coordinator of Tax and Fiscal Justice Asia and Coordinating Committee Member of GATJ commented:
“Taxation is not just a technical issue, it is deeply political and affects development, human rights, gender equality, and climate justice. As we look to the next round of UN tax negotiations which take place at the same time as the COP30 climate negotiations, we must ensure that the new global tax rules integrate the ‘polluter pays principle’ and serve to deliver urgently needed resources to fund climate action.”
Looking Forward: Negotiations in Nairobi
Following the start of the UN Tax Convention substantial negotiations, the next round of negotiations will take place in Nairobi from November 11 to 19, 2025. In between sessions, despite efforts to participate by civil society, discussions will resume online in closed-door meetings. As the negotiations have officially begun on developing this historic convention, GATJ will continue to advocate for the development of a progressive, effective, sustainable, inclusive, and transparent UN Tax Convention.
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