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.
Specifically, the Youth Tax Justice Network (YTJN) will be present at the Fourth INC Session, advocating for youth-inclusive tax governance, intergenerational accountability, and transparent fiscal systems that respond to the social and economic realities facing young people globally. YTJN aims to contribute youth-centered perspectives to ongoing debates on taxing rights, transparency, and international cooperation against tax abuse.
Uganda’s participation in the UNFCCC process continues to affirm our unwavering commitment to global climate action, sustainable development, and resilience building. As one of the Least Developed Countries (LDCs), Uganda remains steadfast in advocating for fairness, equity, and access to finance, technology, and capacity building under the principle of Common but Differentiated Responsibilities and Respective Capabilities (CBDR–RC).
This year’s COP, framed as the “implementation COP,” aimed to move beyond promises and focus on how to make climate commitments real. Yet, deep disagreements on finance, trade, fossil fuel pathways, and other areas delayed progress until the final hours. More than 80 countries pushed for a roadmap to phase out fossil fuels, while many advocates and developing nations called for stronger commitments on climate finance, but the final text fell short of expectations.
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.
Delegates agreed on the importance of preventing disputes before they occur. Yet tools like advance pricing agreements, joint audits, simultaneous examinations, and cooperative compliance programs remain unevenly accessible. Key views included support for a legal basis enabling cross-border preventive cooperation, strong calls for capacity-building, information-sharing, and improved access to timely data, and emphasis on strengthening information systems and exchange-of-information frameworks. Interests were also seen in optional cross-border prevention mechanisms backed by future best practices and CoP-led support.
Delegates at the 3rd Session of the Intergovernmental Negotiating Committee (INC3) continued working toward the development of a UN Framework Convention on International Tax Cooperation. Friday’s discussions focused on Article 11 on capacity-building and technical assistance, the digitalization of tax administration, sustainability and funding, roles of the Secretariat and COP, and updates from Workstream II on cross-border services.
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.
Lurit Yugusuk, speaking for the Youth for Tax Justice Network, reminded the room that harmful tax practices don’t just affect balance sheets, they affect people.“Harmful tax practices erode national tax bases, weakening the capacity to finance education, healthcare, and infrastructure that children and youth depend on.” She called for expanding Article 8 beyond multinational enterprises to include high-net-worth individuals, private investment vehicles, and professional enablers. She also pushed for mandatory public disclosure of tax incentives and public country-by-country reporting, emphasizing that “secrecy has been the lifeblood of harmful tax practices.”