Issues

SC & G-24 Special Issue 2, July 2025

Analysing the Impact of UN and OECD Subject to Tax Rule for G-24 and South Centre Member States

By Suranjali Tandon and Chetan Rao

The Subject to Tax Rule (STTR) is meant to address base erosion and profit shifting in cross –border transactions. The United Nations (UN) and Organisation for Economic Co-operation and Development (OECD)/Group of Twenty (G20) Inclusive Framework have developed models of the STTR that countries may choose to adopt in their treaties. This paper provides a review of these designs of two STTR models and proceeds to estimate the revenue gains for the Intergovernmental Group of Twenty-Four on International Monetary Affairs and Development (G-24) and South Centre Member States that may arise from a STTR that covers different kinds of payments. The OECD STTR is limited to related-party payments and imposes thresholds based on mark-up and materiality, reducing its applicability in practice. In contrast, the UN STTR offers broader coverage, applies to both related and unrelated parties, and does not impose restrictive thresholds, making it more administratively feasible for developing countries. Although the estimated gains from the OECD STTR appear modest due to its narrow scope, the UN STTR shows greater potential. The analysis also highlights data limitations and the need for access to microdata for accurate country-level assessments.

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Research Paper 223, 22 July 2025

Community Based Surveillance for AMR Monitoring: Significance, Requirements and Feasibility in LMICS

By Afreenish Amir

Community based surveillance, in addition to clinical antimicrobial resistance (AMR) surveillance, plays an essential role in AMR and antimicrobial use trend monitoring. Various community-based AMR surveillance studies to monitor trends in AMR and use of antimicrobials have been conducted and shown its potential to facilitate evidence-based interventions and policy making for control of AMR.  Many low and middle income countries (LMICs) lack the necessary systems and resources to establish effective surveillance systems. Specifically, the surveillance capacity at hospitals and other health facilities is limited, and the overall human resource capacity for community-level data collection, analysis, and multi-sectoral coordination is severely constrained. Prior to planning for community based AMR surveillance, a country should have established mechanisms to run the system efficiently, including strong governance and regulations, surveillance infrastructure, laboratory capacities, skilled human resources, data collection and management, funding and sustainability.

The World Health Organization and quadripartite partners have recommended advancing community based AMR surveillance in LMICs, and integrated AMR surveillance combining information from humans, animals and ecosystems, which seems a challenge in the current situation. Considering the significant gaps in systems, resources, and capacities, it is important to prioritize strengthening the country’s core capacities and addressing the underlying gaps in healthcare systems. Efforts should focus on enhancing the country’s core capacities, systems, and technical requirements while exploring the potential of advancing selective community based AMR surveillance interventions and systems in the future.

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South Centre Working Document, 15 July 2025

WTO Reform: Structuring a Positive Agenda for Developing Countries

A Working Document on Structuring Reform Around Legal Principles and Development Priorities, 15 July 2025

By Vahini Naidu, Trade for Development Programme, South Centre

This Working Document outlines a structured contribution to the WTO reform process from a legal and developmental perspective. It organises the wide range of reform issues into seven categories, based on their legal character, institutional handling, and the procedural steps required for meaningful resolution. The aim is to support a more coherent and inclusive reform process by offering a logical framework grounded in the Marrakesh Agreement and reflective of the WTO’s foundational principles. It is intended to assist Members in navigating reform discussions in a manner that is principled, transparent, and responsive to the priorities of developing countries.

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South Centre Informal Note, 15 July 2025

WTO Reform: Framing Challenges in the Facilitator-led Process and Strategic Considerations for Developing Countries

 By Vahini Naidu, Trade for Development Programme, South Centre

This Informal Note was prepared to inform developing country participation in the next round of Facilitator-led consultations on WTO reform. It provides a critical reflection on the three-track framework proposed by the Facilitator, namely Governance, Fairness and Future, and raises concerns about the framing, legal coherence, and process legitimacy of the emerging reform agenda. The note highlights the risks of implicitly reshaping negotiating priorities through informal structuring, particularly in ways that may disadvantage developing countries or dilute existing legal mandates. It offers strategic considerations and suggested responses to the three guiding questions posed by the Facilitator, underscoring the need to reaffirm treaty-embedded rights such as Special and Differential Treatment, preserve institutional integrity, and ensure that any reform remains firmly anchored in multilateral principles, Member-driven processes, and the development dimension. A separate working document proposing a structured positive agenda for developing countries will follow to complement this analysis.

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SC Webinar Report on Gender Intersectionality in AMR, July 2025

Gender Intersectionality in Antimicrobial Resistance 

Webinar Report

The South Centre held a webinar on Gender Intersectionality in Antimicrobial Resistance (AMR), on 14 May 2025, with the participation of experts from academia, independent research institutions and international organizations. The webinar was attended by over 70 participants from around the world, demonstrating interest in gaining greater understanding of the gender dimension in effective strategies for tackling antimicrobial resistance 

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Research Paper 222, 16 July 2025

Designing an Independent Panel on Evidence for Action on Antimicrobial Resistance: Lessons from Selected Bodies in Global Health, Climate Change and Biodiversity

By Viviana Munoz Tellez and Francesca Chiara

This paper proposes a framework for designing an Independent Panel on Evidence for Action on Antimicrobial Resistance (IPEA), responding to the 2025 United Nations General Assembly mandate. Through a comparative analysis of selected international scientific advisory bodies, we identify the panel’s mandate as the foundational element that will critically shape its composition, scope, deliverables, and governance structure. Our framework addresses key domains of credibility, scientific integrity, authority, policy relevance, and sustainability while establishing equity as a fundamental design principle—not merely ensuring low and middle-income country (LMIC) participation but designing the IPEA to address existing imbalances in antimicrobial resistance (AMR) evidence production and dissemination. We analyse potential mandate options, from evidence synthesis to policy recommendations, highlighting the importance of defining a unique and complementary role for IPEA within the existing AMR governance landscape to avoid duplication and maximize impact on global AMR response. 

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South Centre Commentary, 9 July 2025

WTO Reform: Facilitator’s Report on Initial Consultations (JOB/GC/445)

Commentary, 9 July 2025

By Vahini Naidu, Trade for Development Programme, South Centre

This commentary provides a critical analysis of the Facilitator’s Report on Initial Consultations on WTO Reform, highlighting the absence of a shared reform objective, the fragmentation of issues, and the risks posed to developing country priorities, particularly with respect to the Special and Differential Treatment and self-designation, and the consensus-based decision-making. It examines the legal and institutional implications of current reform narratives and cautions against proposals that may entrench rather than correct systemic imbalances.

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Research Paper 221, 15 July 2025

The AI Race: A Tightrope Walk Between Innovation, Inclusivity and Prosperity for All

By Daniel Uribe Terán 

The intensifying global race in Artificial Intelligence (AI) forces nations to walk a tightrope, balancing the drive for rapid innovation against the imperatives of fairness, safety and inclusivity. This tension is reflected in recent high-level international summits and the diverging regulatory paradigms emerging globally, most notably between the market-driven, largely deregulatory approach of the United States and the human-centric, risk-based model favoured by the European Union. Such divergence contributes to a fragmented governance landscape, posing significant challenges for developing countries, which face the risk of marginalisation due to disparities in infrastructure, resources, and technical capacity. Some of these countries have put in place proactive strategies as they endeavour to walk the tightrope between innovation and fairness in the unfolding AI era.  

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SC Inputs on Draft Issues Notes on UNFCITC, 11 July 2025

South Centre Inputs on the Draft Issues Notes on the UN Framework Convention on International Tax Cooperation

11 July 2025

In preparation for the First and Second Sessions of the Intergovernmental Negotiating Committee (INC) on the United Nations Framework Convention on International Tax Cooperation (UNFCITC) to be held in August 2025, the Co-Leads of each of the three Workstreams have released Draft Issues Notes for public comments. The Issues Notes are meant to provide direction on the content of the UNFCITC and its two early protocols on services and dispute prevention and resolution.

There are three Issues Notes:

1. Workstream I on the framework convention

2. Workstream II on the taxation of services

3. Workstream III on dispute prevention and resolution

The South Centre submitted inputs on all three Issues Notes on 11 July 2025 which are reproduced below:

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South Centre Statement – 66th WIPO Assemblies, July 2025

South Centre Statement to the 66th WIPO Assemblies

July 2025

At the WIPO Assemblies, the South Centre calls for a balanced IP regime that supports development, links to the SDGs, and preserves national policy space. We back the GRATK Treaty, TK & TCE negotiations, and a Development Acceleration Fund.

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SC Statement – FFD4 DRM Seville Declaration Side Event, 1 July 2025

Domestic Revenue Mobilisation at the Heart of Sustainable Development: the Seville Declaration

Side-event at the Fourth Financing for Development Conference (FFD4), co-hosted by the South Centre, EU Commission, Germany and Nigeria

High Level Statement by Dr. Carlos Correa, Executive Director of the South Centre

Addis Tax Initiative (ATI) member the South Centre co-organized an event with fellow members the EU Commission, Nigeria and Germany at FFD4 on ‘Domestic Revenue Mobilisation at the Heart of Sustainable Development: the Seville Declaration’. Here are the remarks of Dr. Carlos Correa, Executive Director of the South Centre at the event.

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South Centre Statement at FfD4, 30 June – 3 July 2025

South Centre Statement on the Fourth International Conference on Financing for Development

Seville, Spain, 30 June – 3 July 2025

The international financial architecture continues to reflect a global order that existed eight decades ago. An urgent, comprehensive reform is needed to make such order responsive to the financing needs of developing countries in the 21st century.

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