International tax regimes are based on bilateral agreements entered into by sovereign states. The templates for such treaties are those of the Organisation for Economic Co-operation and Development and the United Nations Model Conventions. To further the interests of the international community, efforts are underway to draft a multilateral instrument addressing pressing issues in international taxation. The UN is working to establish a Framework Convention on International Tax Co-operation, also known as the Model Tax Convention.

During the past year and a half, successful stakeholder meetings have led to the publication of a revised draft, establishing its core principles. Follow-up online stakeholder discussions, organised by the UN Intergovernmental Committee (UN IGC) in June 2025, led to the setting up of three workstreams. Fundamental to each was the concept of fairness. This is recognised as the foundation of the rules governing international taxation. It also reveals the lack of a definition of fairness in international tax treaties.