Report

A Roadmap for Negotiating the Protocols to the United Nations Framework Convention on Tax

This report examines the early protocols on cross-border services taxation and dispute resolution, as well as other identified priority and potential protocols under the United Nations Framework Convention on International Tax Cooperation (UN FCITC). For each early or potential protocol, the report outlines its importance, reviews ongoing efforts, identifies key challenges, and assesses how the Convention could advance the issue.

By Annet Oguttu, Alexandra Readhead, Josefina del Rosario Lago, Suzy H. Nikièma, Kudzai Mataba, Juliana Midori Kuteken, Elisângela Rita on July 16, 2025

This publication provides an analysis of the UN FCITC, focusing on its role in shaping a more inclusive and effective global tax architecture. It examines the two early protocols selected for immediate development: the taxation of income derived from cross-border digital services, reflecting the challenges of an increasingly digitalized economy; and the prevention and resolution of tax disputes, which remain a significant hurdle in international tax governance. 

The report also addresses a broader set of priority and potential protocols that the Convention seeks to develop, including measures targeting digital taxation, tax-related illicit financial flows, the taxation of high-net-worth individuals, environmental tax cooperation, exchange of information for tax purposes, mutual administrative assistance, and combating harmful tax practices. 

For each protocol, the report delves into why the issue is critical for international tax cooperation, assesses ongoing national, regional and global initiatives, and evaluates the challenges and shortcomings faced by existing frameworks. It further offers preliminary insights into how the UN Framework Convention and its protocols could fill gaps and strengthen mechanisms to address aggressive tax avoidance and evasion. 

This roadmap aims to inform negotiators, policy-makers, and tax authorities about the strategic considerations necessary to advance global tax governance in a manner that is effective and inclusive.

Report details

Topic
Taxation
Impact area
Sustainable Economies
Publisher
IISD
Copyright
IISD, 2025