The UN Framework Convention on International Tax Cooperation is a proposed international legal instrument, or treaty, intended to create a fairer and more effective global tax system. Its origin traces back to December 2022, when the UN General Assembly adopted Resolution 77/244, launching discussions on international tax cooperation, followed by Resolution 78/230 in December 2023, which established an Ad Hoc Committee to draft its Terms of Reference. The Convention was championed by the Africa Group and other developing countries to solve the problem of an international tax system largely shaped by the OECD, which often excluded the Global South and favored wealthy countries, limiting the taxing rights of developing nations.
The Convention works as a framework that sets out broad objectives, principles, and a governance structure for future international tax cooperation. Its objectives include establishing an inclusive, fair, and transparent system that supports sustainable development and addresses tax abuse by multinational enterprises and high-net-worth individuals. The substantive, technical rules are being developed through separate, legally binding Protocols. The first two protocols, for which draft texts were released in July 2026, cover the taxation of income from cross-border services (Protocol I) and the prevention and resolution of tax disputes (Protocol II).
This new framework connects to and aims to reform the existing international tax architecture, which is currently dominated by the OECD-led system and its initiatives like the Base Erosion and Profit Shifting (BEPS) Inclusive Framework. The Convention is a historic shift because it moves rule-making to the universal UN setting, where every country has an equal voice, unlike the OECD. The draft Convention, released on July 21, 2026, includes a provision, Article 21, that contemplates the alignment of existing international tax agreements with the new Convention, potentially requiring the renegotiation of existing bilateral treaties. Negotiations are expected to continue through 2027, with the final texts targeted for submission to the UN General Assembly in September 2027.