





The leaders committed to “strengthen measures to curb corrupt borrowing and lending, including by enhancing domestic legal frameworks as appropriate, including clarifications regarding the authority to borrow, and fully utilizing UNCAC and its Conference of the State Parties to explore options to make such contracts unenforceable. We will establish a platform for borrower countries with support from existing institutions, and a UN entity serving as its secretariat.
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The third intergovernmental session on the UN Tax Convention, hosted in Nairobi, Kenya, has three main objectives: to review the draft text of the Framework Convention negotiations to reach a common understanding on the articles and protocols and develop a more coherent text in the coming months; to provide updates on progress made during the intersessional period on Protocol 1, concerning the taxation of income from cross-border services, with a view to presenting potential options and approaches for the committee’s consideration during the 4th session in February 2026; and to turn to Protocol 2, where the workstream has begun developing preliminary approaches outlined in the concept note.
The Third Session of the Intergovernmental Negotiating Committee (INC-3) focused on advancing substantive negotiations on the UN Framework Convention on International Tax Cooperation and the Protocol on Prevention and Resolution of Tax Disputes. The programme of work was structured across two weeks, combining formal, informal, and closed meetings.
The conversation then drifted on questions on how to handle disputes in the absence of tax treaties. For developing countries, the answer was simple … “No treaty, no dispute-resolution mechanism.” For them, the Protocol should not create new legal bases.
But across the room, private sector voices insisted that disputes do not wait for treaties; businesses struggle with uncertainty, and governments lose revenue. They pressed for innovations, with some calling for strengthening MAP, others calling for coordinated unilateral Advance Pricing Agreements (APAs), and others for the view that temporary unilateral relief would prevent double taxation.
YTJN welcomes the opportunity to contribute to this historic process. As a global youth-led network, we stress that international tax rules must prioritize intergenerational justice, equitable public service financing, and youth participation in decision-making. Tax policy directly impacts young people’s access to education, healthcare, climate resilience, and economic opportunities.