The First Session of the historic Intergovernmental Negotiating Committee (INC) on the United Nations Framework Convention on International Tax Cooperation officially opened on August 4, 2025, at the UN headquarters in New York, USA and went through to August 15, 2025.
Intervening during the session on behalf of the African Union, Department of Economic Development, Trade, Tourism, Industry and Minerals (ETTIM) Dr, Patrick Ndzana Olomo, Ag. Director, Economic Development, Integration and Trade, AUC, aligned his contribution with the position of the African Group of Permanent Representatives (PR) to the UN, noting that this is the first time in history that experts from across the globe gather to create a new, shared principle driven Framework Convention on International Tax Cooperation. In his remark, Dr. Olomo posited:
“We gather today to shape commitments that will underpin a transformative UN Framework Convention on International Tax Cooperation. This is a generational opportunity to correct structural injustices and institutional gaps in the global tax order, an order that has long marginalised source jurisdictions, especially across the African continent”. He added that “the recent G7 announcement regarding Pillar Two exemptions reminds us of the current broken and unfair tax architecture. The African Union is here with hope and determination to co-create a system that works for all, rooted in equity, transparency, and the sovereign right of every nation to raise revenue justly.”
On the three workstreams discussed during the sessions, Dr. Ndzana highlighted the African Union priorities, including the following:
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Workstream I, on the framework convention, should develop the Convention's structural and governance elements, such as the Conference of the Parties, the Secretariat, and Subsidiary Bodies, due to their foundational role and the need for sufficient elaboration time;
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Workstream II, the first early protocol on Taxation of Income Derived from the Provision of Cross-border Services in a Globalised and Digitised Economy should be future proof, covering digital and emerging services. It must uphold the principle of taxing where real economic activity and value creation occur, recognize user data and user participation as factors in value creation, follow simple rules, and include a multilateral solution to overcome existing tax treaty limitations; and
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Workstream III, the second early protocol on Prevention and Resolution of Tax Disputes, should address cross-border tax disputes that disadvantage countries with limited access mechanisms like Mutual Agreement Procedures and arbitration. “We call for a fair, accessible, and balanced dispute resolution framework that avoids replicating investor-State arbitration inequities”. The African Union opined that such a framework could be realized through a commitment in the Convention to fair, inclusive, efficient, and timely mechanisms that prioritise accessibility and equity for all countries, especially those with limited treaty networks and administrative capacity.
The sessions concluded by affirming the growing convergence among UN Member States on the need for a strong framework convention on international tax cooperation, alongside a clearly defined scope for the two early protocols, an approach long and consistently championed by the African Union and the African Group.
The next session of the Intergovernmental Negotiating Committee will be held in Nairobi, Kenya, from 10 to 21 November 2025, where draft negotiating texts for the Convention and its protocols will be tabled for consideration.
The African Union, acting on the Mandate of the Specialised Technical Committee on Finance and Monetary Affairs, is committed to working collaboratively with Pan-African Organisations including the African Tax Administration Forum (ATAF), the United Nations Economic Commission for Africa (UNECA) and Tax Justice Network Africa (TJNA) to provide Member States with the technical support needed to ensure a unified and amplified African voice in the negotiations.
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