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The Co-Leads of the Intergovernmental Negotiating Committee (INC) of the United Nations Framework Convention on International Tax Cooperation (UNFCITC) released the first draft of the Framework Convention Template on 24 October 2025. The subsequent discussions in Nairobi dissected a host of issues, from taxing rights to the taxation of high-net-worth individuals, and such discussions are expected to continue as the Committee crystallises the text of the Convention for a meaningful, inclusive future.

This column was published in the India Business Law Journal. It discussed the pressure points for the Nairobi session and how they would interact with future negotiations in New York and beyond.

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