This publication focuses on the design of the Second Protocol on tax dispute prevention and resolution.

It draws on compliance and enforcement models from human rights and trade treaties to propose a hybrid mechanism that ensures fairness, efficiency and accessibility. The report recommends a multi-tiered system with binding decisions, robust oversight, and capacity-building support, particularly for Global South countries, to foster an equitable and enforceable global tax dispute architecture grounded in human rights.

This publication is part of a series, which you can find here.