The United Nations (UN) is set to finalise and adopt a new UN Framework Convention on International Tax Cooperation and two early protocols by the end of 2027. The mandate for the negotiations is the terms of reference, which was adopted at the end of 2024. 

The first round of substance negotiations will be taking place from 4-15 August 2025.

Ahead of the negotiations, three key documents from the UN were published for consultation at the end of June 2025. These concern: 

• Workstream 1 - the Convention;
• Workstream 2 – an early protocol on taxation of services;
• Workstream 3 – an early protocol on dispute prevention and resolution. 

In response to the consultations, joint submissions for all three workstreams were submitted by a group of over 100 civil society organizations and trade unions – coordinated by the Global Alliance for Tax Justice. These submissions outline the group’s expectations for the upcoming negotiations and are summarised below. 

Furthermore, all submissions, including those from UN Member States, can be found online here. 

Summary of the joint submissions by over 100 civil society organisations and trade unions to the UN Tax Convention negotiations

For all three workstreams, the group of signatories welcomes the approach taken and the suggested timeline. Furthermore, the group stresses the importance of full and effective participation of civil society organizations and trade unions in the negotiations, including online meetings of the Workstreams.

Submission to Workstream 1 – the Convention

In the joint submission to Workstream 1, the group of signatories welcomes the idea of having commitments in the Convention that can take effect directly - without needing an additional protocol to be negotiated. Furthermore, the submission includes specific issue-related comments on the future commitments related to the fair allocation of taxing rights, including equitable taxation of multinational enterprises. In this context, the group calls for the transfer pricing system to be replaced with a unitary tax system. 

Paragraph 10 of the terms of reference also mentions that there will be a commitment in the future Convention on taxation and sustainable development. In this context, the undersigned group of signatories draws attention to the Compromiso de Sevilla, including important decisions related to progressive taxation, gender, human rights and environment. In the submission, the group also stresses the importance of adding a sub-commitment on progressive environmental taxation in line with the polluter pays principle. 

Furthermore, the submission includes points related to differentiation, as well as future commitments related to taxation of high-net worth individuals and transparency. 

Lastly, the group draws attention to other elements that they believe should be covered by Workstream I, including principles, preamble, mechanisms, subsidiary bodies and compliance measures. 

Click here to read the submission to Workstream 1

Submission to Workstream 2 – an early protocol on taxation of services

In the joint submission to Workstream 2, the group of signatories underlines that strengthening taxation of the digitalized economy can provide important additional revenues for countries already in the short term. However, in line with the submission to Workstream I, the signatories also stress that they believe the transfer pricing system should be replaced with a unitary system. With that in mind, the group suggests that Workstream II gives consideration to solutions that can be applied both before and after such a reform.

The submission also contains comments on specific issues, including nexus rules, value creation and the role of capacity building. As regards the many problems associated with bilateral tax treaties, the group calls for truly multilateral solutions to reform and replace the role that these treaties play today. 

Furthermore, the submission includes comments on the potential goals of the future Protocol, and the group stresses that these should be fully aligned with the objectives of the Terms of Reference. 

Click here to read the submission to Workstream 2

Workstream 3 – an early protocol on dispute prevention and resolution

In the submission to Workstream 3, the group of signatories provides specific comments on the potential goal of the future Protocol, and stresses that this should be fully aligned with the Terms of Reference. The submission also includes comments on specific issues, including the relation between the Protocol and existing international tax disputes, and the group highlights that the transfer pricing system is a key cause of such disputes. In line with the submissions to the two other workstreams, the group calls for this system to be replaced with a unitary system. 

The submission also includes specific comments on the issues of comparables, advance pricing agreements and the need for public country by country reporting. Furthermore, the group calls for truly multilateral solutions to reform and replace the role that bilateral tax treaties play today, and caution against opt-in opt-out approaches. Finally, the group highlights their concerns concerning mandatory arbitration. 

Click here to read the submission to Workstream 3