
Series: International Law at the UN Tax Convention
From 2025 to 2027, UN Member States will engage in intergovernmental negotiations towards a Framework Convention on International Tax Cooperation. This process could establish a new multilateral norm-setting space to address structural asymmetries in global tax governance and strengthen the fiscal capacities of all States to deliver on human rights and sustainable development commitments.
The convention offers a legally binding vehicle to tackle illicit financial flows, abusive tax practices and profit shifting by multinational enterprises, core barriers to equitable resource mobilisation and systemic reform.
As negotiations progress, the legal architecture of both the framework convention and its protocols will be critical to ensuring coherence, enforceability and alignment with international law. Substantive provisions must be precise, normatively sound and institutionally operable.
This series provides international legal analysis tailored to the convention process, aiming to inform negotiators, civil society and other stakeholders. By bridging disciplinary divides and unpacking legal dimensions of key issues, it supports the design of a coherent, effective and rights-aligned international tax instrument.
Publications
Taxpayers’ Rights and the UN Tax Convention: Addressing the Weaponisation of Privacy and Confidentiality to Reinstate Tax Transparency in Favour of Tax Justice
This publication argues that the UN Tax Convention offers a vital chance to shift global tax governance towards greater transparency and justice, aligning taxation with human rights obligations. While civil society secured key wins, like recognising the link between tax cooperation and rights fulfilment, some countries, especially in the Global North, are pushing to limit transparency under the guise of protecting privacy. Our paper contends that such narratives serve the interests of wealthy individuals and multinational corporations who exploit secrecy and legal loopholes to avoid taxes, thereby deepening inequality and depriving governments of funds for essential public services. This publication calls for robust, rights-based tax transparency measures to ensure accountability, fairness and sufficient public revenue.
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Legal and Procedural Lessons from International Treaties for Multilateral Tax Treaty Negotiations
This publication focuses on legal and procedural lessons from past multilateral treaties to inform the design of the Second Protocol on tax dispute prevention and resolution. Analysing key success factors like inclusivity, enforcement, flexibility, civil society engagement and financial support, the report offers policy recommendations to help build a fairer, more effective, and human rights-aligned global tax system.
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Comparative Legal Insights for the Second Protocol on the Prevention and Resolution of Tax Disputes
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.
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