





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.
For young people across Africa and the world, these negotiations represent more than just policy debates. They offer an unprecedented opportunity to shape an economic future focused on intergenerational equity, where every resource counts, and where fiscal justice becomes a tool for equality, innovation, and opportunity.
We recognize that the youth of Southern Africa represent an immense reservoir of energy, creativity, and potential that is critical to the continued progress and prosperity of our communities. As present leaders and change-makers of our region, we have a vital role to play in addressing the complex social, political, economic, and environmental challenges that we face. We have a role to complement our governments, the private sector, and all developmental actors to ensure access to quality and affordable education for the SADC child.
Africa, home to the youngest and fastest growing population globally, has faced shrinking fiscal space, capital flight, and uneven access to international financial markets. For African youth, who not only represent over 70% of the continent’s population but also the continent’s potential drivers of innovation and growth, these challenges translate into restricted opportunities, heightened vulnerabilities, and a fragile future.
We write to you as the Youth for Tax Justice Network (YTJN), a global, youth-led coalition advocating for inclusive and equitable
tax systems that serve the needs of both present and future generations across Africa and Europe. As the Intergovernmental
Negotiating Committee deliberates on the United Nations Framework Convention on International Tax Cooperation in New York,
we urge you to recognize this moment for what it is: a generational turning point.