Overview

The United Nations General Assembly established the Intergovernmental Negotiating Committee, with the objective of drafting a United Nations Framework Convention on International Tax Convention and two early protocols. The proposed Convention seeks to position itself as an international instrument with the aim of improving global tax cooperation. This process is scheduled to run from 2025 to 2027. The draft text of the Framework Convention on International Tax released by the UN, on the 24 th of October 2025 seeks to codify some of the articles in detail ahead of the third round of negotiations in Nairobi, scheduled for the 10 th to 19 th of November 2025.

Boutonnière of Provisions

Article 4
The co-leads have, in an effort to codify the rules to regulate the ‘Fair Allocation of Taxing Rights’ under Article 4, sought to identify that all source jurisdictions where the taxpayer conducts business and where the value is created will be able to tax the income generated from these businesses.