UN Tax Convention — Negotiating the Rules That Decide Tax Havens' Fate

Four negotiating rounds in, a draft UN tax treaty is taking shape. Here is what has actually changed.
UN Tax Convention logo
Follow the Money

UN Tax Convention — Where the Negotiations Actually Stand

RYB’s Tax Havens page describes the problem this convention exists to fix: hundreds of billions of dollars disappearing into offshore structures every year, money that would otherwise fund exactly the public services the Sustainable Development Goals are meant to expand. This page follows the proposed solution as it is actually being negotiated, article by article, session by session, at UN headquarters and beyond.

The UN Framework Convention on International Tax Cooperation is the first attempt in history to write global tax rules with all 193 UN member states at the table, rather than the smaller, OECD-led club of mostly wealthy countries that has set the terms until now. It is not a finished treaty. It is a live negotiation, currently in its fourth full round, with real text now on the table and real disagreements still unresolved.

How the Process Reached This Point

The push for a UN-led alternative to OECD tax governance built for years before it became official. In December 2023, the UN General Assembly passed Resolution 78/230, establishing an Ad Hoc Committee to draft the convention’s terms of reference. That committee’s work culminated in a vote on 16 August 2024 that exposed the global divide driving this whole process: 110 countries in favour, only 8 against, Australia, Canada, Israel, Japan, New Zealand, South Korea, the UK, and the US, with 44 abstentions, mostly other wealthy nations hedging their position. The General Assembly confirmed the formal three-year negotiating process that November, by a similarly lopsided 125 to 9 margin.

What followed was the slower, less visible work of actually building an institution. An organisational session in February 2025 elected a Bureau of twenty members, one chair, eighteen vice-chairs, and a rapporteur, drawn from the UN’s five regional groups, and settled on a structure of three workstreams: the Framework Convention itself, plus two early protocols on the taxation of cross-border services and on dispute prevention and resolution. Egypt’s Ramy Youssef, Assistant Minister of Finance for Tax Policy and Reform, chairs the committee.

Four Sessions In, and the Draft Text Now Exists

The real negotiating began in August 2025, in New York, the first time substantive language was actually discussed rather than process and procedure. A third session followed in Nairobi from 10 to 19 November 2025, the first time the talks moved outside UN headquarters in New York, a symbolically significant choice given how much of this process is about shifting tax governance away from wealthy-country capitals.

The fourth session, held in New York from 2 to 13 February 2026, marked the clearest turning point so far: negotiators worked from an actual co-leads’ draft template for the Framework Convention for the first time, alongside a detailed options paper on taxing cross-border services and a concept note on dispute resolution. The Tax Justice Network, which has tracked every session live, described the talks as having moved from scoping core elements to examining detailed draft text across the Convention and both protocols. Where the previous page on this site could only report that negotiations were continuing, there is now an actual document to argue over.

That document is revealing real fault lines. Article 4, on whether sustainable development, inequality, and human rights should be binding operational principles or only high-level guidance, remains a genuine sticking point: civil society groups want the commitment anchored to measurable progress, while several governments warn that overly broad language risks exceeding what a framework convention can practically enforce. Article 5, on the fair allocation of taxing rights, has split along a similar line to the OECD-era debates this convention was meant to move beyond, with wealthy countries and investment hubs generally preferring net-basis taxation and Global South delegations preferring gross-basis approaches, which are administratively simpler and offer more predictable revenue for countries with less capacity to audit complex corporate accounts.

What Comes Next

The roadmap adopted by member states calls for the Intergovernmental Negotiating Committee to meet three times a year through 2027, when a final convention text and both protocols are due for submission to the UN General Assembly’s 82nd session. The fifth session is scheduled for 3 to 14 August 2026, and stakeholders including the Tax Justice Network describe it as “crunch time,” the point at which all three workstreams are expected to produce genuine new draft text rather than options papers and concept notes. A Zero Draft of the full Framework Convention is the next major milestone the process is building toward.

None of this guarantees an outcome. The same divisions visible in the 2024 votes, wealthy countries protective of the OECD process they currently lead, developing countries insisting on a seat they have never previously had, are still visible inside the actual drafting language eighteen months later. What has changed is that the argument is no longer about whether to negotiate. It is about exactly what the text says, line by line, which is both a sign of real progress and the point at which negotiations most often stall.

RYB’s Place in This Picture

RYB does not have a seat at this negotiating table, and does not pretend to. The Tax Justice Network, the Global Alliance for Tax Justice, the Center for Economic and Social Rights, and dozens of other civil society organisations are doing the detailed, session-by-session monitoring this page draws on, often with far more technical depth than any single page could carry. What RYB can do, consistent with the rest of this Finance section, is keep this process visible to an audience that would otherwise only hear about it, if at all, as a single headline vote rather than the years-long drafting process it actually is. The connection back to Tax Havens and the wider Finance section is the point: this convention is the one process currently underway that could change the numbers reported on every country page in this network, including the Netherlands’ own red rating on Corporate Tax Haven status.

Looking Forward

A convention text due in 2027 is still a convention without legal force until individual countries ratify it, the same gap between agreement and implementation that shapes every page in RYB’s Finance section. But the distance this process has already covered, from a single 2023 resolution to an actual draft template with named article disputes, is real, and worth tracking precisely because so few people outside the negotiating room are watching it happen. RYB will keep returning to this page after each session, the same way the country pages return to each year’s Sustainable Development Report. The next checkpoint is August 2026, and the one after that is the Zero Draft itself.

Sources

Official UN Documentation
Civil Society Tracking and Analysis
Wealthy-Country Positions
Share this story: