SC Inputs on Workstream I – Co-Lead’s Zero Draft of UNFCITC, 26 August 2026

South Centre Inputs on Workstream I – Co-Lead’s Zero Draft of UN Framework Convention on International Tax Cooperation

26 August 2026

1. Fair allocation of taxing rights should include nexus factors based on OR rather than AND, should specify methods of allocation and be de-linked from the objective of avoiding double taxation.
2. Conference of State Parties (COSP) should be the supreme body for administering the Framework Convention (FC) and the Protocols and any other instruments it produces, be able to undertake any actions required to achieve the objectives of the FC, and should be able to make decisions by simple majority vote.
3. Amendments to the FC and adoption of the FC’s Protocols should also be by simple majority.
4. All Parties to the FC and its Protocols should make regular and mandatory contributions. This is essential for the success of the UNFCITC. Sustained non-payment should result in denial of voting rights, as is currently the practice in the UN General Assembly under Article 19 of the UN Charter.
5. The commitment to align existing tax treaties, domestic law and other instruments with the FC and its Protocols should not be request-triggered, and the COSP should determine a timeline by when it will be done.
6. The COSP shall take measures to ensure that no Party to the FC is prevented from implementing the Convention, its Protocols and any other instruments adopted by the COSP.

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South Centre Inputs on Workstream I – Co-Lead’s Zero Draft of UN Framework Convention on International Tax Cooperation