To honour the South Centre’s 30th Anniversary, we are pleased to feature reflections on the South Centre’s work over the years. We invited entities and individuals to share brief remarks on how the South Centre has contributed to support development efforts or, specifically, to their own work—whether through the Centre’s policy support, technical assistance, capacity-building, or advocacy. These reflections highlight the strength of South-South solidarity and the impact of our collective efforts over the years. We were grateful to receive the remarks compiled in this document and deeply appreciate the contributions to this celebration of the South Centre.
Comparison of Tax Revenue Effects of United Nations and OECD Subject to Tax Rule for G-24 and South Centre Member States
By Faith Amaro and Sol Picciotto
The Subject to Tax Rule (STTR) seeks to address the historical imbalance in the allocation of taxing rights under international tax treaties by introducing within existing treaties a new article which makes the restrictions on source taxation conditional on the residence jurisdiction imposing a minimum level of tax on foreign-derived income. This paper presents a methodology for analysing the respective benefits of the STTRs developed by the Organisation of Economic Co-operation and Development (OECD) and the United Nations (UN). Applying this model to publicly available data for 2021, it also provides estimates of the possible revenue impact for the 65 Member States of the South Centre (SC) and the Intergovernmental Group of 24 (G-24). Our analysis indicates that the OECD STTR would have no impact on any OECD country treaty with a SC/G-24 Member State. Applying the prescribed 9% minimum rate to covered payments, only 100 treaties across 28 SC/G-24 Member States would qualify for improvement under the OECD STTR, with an estimated combined revenue gain of USD 55.6 million, 71% of which is concentrated in just five treaties. In contrast, the UN STTR, which does not specify a minimum rate, was modelled using rates of 9%, 10% and 15%. This resulted in estimated revenue gains of USD 212 million, USD 325 million, and USD 1,165 million across 171, 210 and 317 treaties, respectively. Given its complexity and restrictive scope, it seems pointless for any SC/G-24 Member State to join the OECD STTR. Instead, countries should focus on identifying treaties that cause unjustifiable revenue losses and consider revising them – either by adopting the simpler and broader UN STTR or implementing other measures such as active anti-abuse provisions to combat treaty shopping and tax avoidance.
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.
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.
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.
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 fortackling antimicrobial resistance.
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.
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.
Policy in Practice: Implementing Antimicrobial Stewardship Post-COVID-19
Q&A and Commentary
By Dr Rasha Abdelsalam Elshenawy
This report summarises the key questions and expert commentary for the South Centre, as well as the South Centre Policy Brief on lessons from the COVID-19 pandemic, to strengthen antimicrobial stewardship and provide practical recommendations discussed during the South Centre webinar on “Strengthening Antimicrobial Stewardship: Policy Insights from COVID-19 and Future Pandemic Preparedness.”
Advancing Women and Girls’ Health in a Time of Converging Crises
South Centre Briefing Session (April 2025) Report
The South Centre hosted a high-level briefing session aimed at advancing the health rights of women and girls in the face of multiple global challenges. The meeting coincided with the South Centre’s 30th anniversary and the 30th anniversary of the Beijing Declaration and Platform for Action, bringing together ambassadors, health experts, and representatives of international organisations to discuss the protection and advancement of sexual and reproductive health and rights (SRHR) in the Global South.
Scope of Compulsory License and Government Use of Patented Medicines
To meet public health needs governments can use compulsory licenses and government use as a tool for procurement and import of patented medicines. These mechanisms are provided for in most laws worldwide. The WTO TRIPS Agreement, as reaffirmed by the Doha Declaration on TRIPS and Public Health, recognises the right of WTO members to grant compulsory licenses and their freedom to determine the grounds upon which such licenses may be granted.
This table provides information of instances of their use.
