Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation - First Substantive Session 2025, 4th meeting Economic and Social Council Date: 5 August 2025 Language: English Transcript: https://transcripts.un.org/ar/asset/k1n/k1n6tfw2oe?lang=en Transcripts available through this tool are created by using automatic speech recognition and are not official records nor official documents of the United Nations. Official records and official documents are available on the Official Document System of the United Nations. --- Chair [0:00]: Good afternoon, everyone. So now we are going to resume our discussions on the convention, on workstream one, the framework convention on tax cooperation. We end at the point of, we've closed the last session by completing our discussions on the effective tax prevention and resolution for tax disputes. And I think now we are, we should start our discussion on the second commitment, which is sustainable development. But before we start and open the floor for discussions on sustainable development, I would like to ask if still anyone needs to highlight or have any comment or intervention on the first commitment, which is effective tax effective tax prevention, uh, and resolution for disputes. Okay, looks like no more interventions in this topic. So now we're gonna start our, uh, discussions for the commitment number two, which is the sustainable development. The floor is opened. So as I see no one requesting the floor, so after the lunch break, of course, I think it's expected. So maybe we'll do sort of refreshment. So Daniel will go again through the slides related to sustainable development to remind everyone with what we were talking about. Hopefully, we... So we have a request from Nigeria, so we'll ask Nigeria just to wait till, uh, Matthew just remind everyone of, of what we have in the sustainable development, then we will start with, with the Nigeria intervention. Daniel, the floor is yours. Daniel [3:10]: Okay. All right. Thank you, Chair. So on the commitment on sustainable development, what we, the discussions generally were on that, what was in the commitment, what was the wording used in the commitment was basically adequate. So the West Stream decided to come out with some proposed wording that could be not generally a text, but what the text could look like, and reproduced what was in sub-paragraph c of paragraph 10 of the text with just a little amendment. So the language will be that, will look like taking into account the different capacities of the states. So looking at the various different, the various capacities of the states, I've lost my notes. Kitty, I've lost it. There's nothing. It keeps disappearing. It keeps disappearing. Let me check my laptop. Okay, fine. Thank you. Okay. All right. So what we decided to look at in terms of proposed text, with that taken into account the different capacities of the various states, the state parties agreed to pursue international task cooperation approaches that will contribute to the achievement of sustainable development in its three dimensions, economic, social, environmental, in a balanced and integrated manner. Now, the idea was that when we look in the UN circles, there's already quite a lot of discussions on this or what is understood by this in the UN circles. So that's why we came out with this. So what we're asking the committee to look at is, are there any other approaches to sustainable development that we may have left out of what we have here, of this text that is here? and in that sense, are there additional paragraphs that we need? Or what we have here, basically, picked from the TUR is enough and is broad enough that allows us that in the future, if we need to come out with any protocols, it will be sufficient for that matter. So that's what we have. Chair [5:54]: Thank you, Daniel. Nigeria. Nigeria · Africa Group [6:01]: Thank you very much, Chair, and thanks Daniel for leading us through this. I speak on behalf of the African group and as to the specific issues of commitment as regards sustainable development, the African group says that the whole discussion about the framework convention is not abstract. and it is meant for a purposeful goal, which is to ensure that we are able to implement the sustainable development goals of the UN in all countries, including African countries. And therefore, the issue of domestic revenue mobilization is key to the achievement of that goal. And so whatever convention and framework we are coming up with, must be able to lead to the achievement of that goal. Now coming back to specific question as to what we currently have in the relevant paragraphs, whether it is broad and sufficient enough, we are of the view that the language that is proposed is appropriate and also captures the whole intention of ensuring that states are able to generate revenue on their own and be able to also ensure that we have sustainable development in all developing countries as well as also in developing economies. However, we seek that if there are any aspects that are left out, we are open to discussing. those aspects, but we believe that the current language is good and is able to capture the essence of sustainable development. Thank you. Chair [8:17]: Thank you. Thank you, delegate of Brazil. Brazil [8:23]: Thank you, Chair. Uh, first of all, we congratulate the Chair, the Secretariat, and the co-lead for the present preparation of the issues note, which will provide guidance to the negotiating committee along with, uh, the terms of reference. We welcome the opportunity to contribute to the discussion on how sustainable development should guide the design and implementation of the UN Framework Convention on International Tax Cooperation. To be meaningful, the convention must embed sustainable development as a foundational commitment, not only as a goal, but as a driver of the rules we establish. This means incorporating normative and operational elements that align tax cooperation with our shared commitment to the 2030 agenda. First, this includes ensuring the equitable allocation of taxing rights so that all countries, especially developing ones, have the ability to tax cross-border activities that occur with or target their economies. This principle promotes both fairness and domestic resource mobilization essential for development. Second, international tax cooperation must reinforce the whole of progressive taxation and structural reform aiming for more balanced economic development. Taxation is a vital tool for addressing inequality, enabling inclusive growth and funding social protection system core to SDGs one and 10. Third, the convention should help countries to enhance their fiscal space, allowing countries the policy autonomy to shape tax system that support domestic resource mobilization and their own development pathways while responding to social environment imperatives, including climate actions under SDG 13. Finally, the framework convention must also help members to ensure the financing of public goods, public education, health care, climate resilience, infrastructure, and so on, areas that require collective effort in both regional and international levels. In some, sustainable development should not be a secondary consideration. It must shape the very architecture of international tax cooperation under this convention. So thank you. Chair [11:20]: Thank you. The distinguished delegate of India. India [11:24]: Thank you, Chair. And as most of the distinguished delegates before us have said, we are generally happy with this language that has been presented. We also would like to point out that the concept of sustainable development has been mentioned several times in the terms of reference. The objectives at 7C clearly mention that one of the objectives would be to establish an inclusive, fair, transparent, efficient, equitable and effective international system for sustainable development, and it goes on to speak. of strengthening domestic resource mobilization. And thereafter, it also finds its place in the principles and then the commitments. So I think put together all the elements of the terms of reference, which will then be reflected in the framework convention, I think it takes into account all the various issues or factors that would be relevant for the issue of sustainable development. So I think the language that is, is now presented in paragraph 17 of the issues note is something that, uh, we sh- we can, we can accept. Thank you. Chair [12:50]: Thank you. Distinguished delegate of. Canada [13:51]: Canada. Thank you, Mr. Chair. Canada's stance is in line with the terms of reference And that language was reflected in the issue note too. In the preamble, we agree with the language which talks about the capacity of Member States, and we agree with the interpretation there, but perhaps you could explain a little bit the reasons that led to the change in the language of the issue note. I would appreciate a clarification. Thank you. Chair [15:03]: Thank you. Speaker 12 [15:59]: Thank you, Chair. First of all, we'd like to thank the co-leads for their work on the workstream and for drafting the documents on the framework convention. In line with what Brazil said, we acknowledge the need to strengthen the international tax system. to improve the mobilization of domestic resources in order to attain sustainable development as well as social economic development as well. These, this is in line with the SDGs and this is, this should be At the forefront of our mind as we go about building the framework convention, we need to make sure that we, on the one hand, enhance resources to finance the necessary expenditure to ensure that we can attain the SDGs effectively. And this is a challenge that many emerging countries are facing, in particular in the current context where there are increasing domestic financial pressure. And on the other hand, the initiatives adopted should be in line with all of the SDGs, particularly when it comes to environmental sustainability and people's well-being, to ensure particularly that high net worth individuals are appropriately taxed. We think this should be at the forefront of our minds, in line with what Nigeria said, we shouldn't overlook the different capacities that different jurisdictions have given the different levels of development that exist. We need to have inclusive languages that reflects global diversity and that reflects the various initiatives that are already underway. Thank you. Chair [17:52]: Thank you. Thank you, delegate of Saudi Arabia followed by Zambia. Saudi Arabia [17:59]: Um, we just would like to echo the comment, uh, made by our, um, distinguished guest from India and, um, Nigeria on the language as presented, we think it is, um, well established and appropriately, uh, framed for the inclusion in the, uh, framework convention, so we do support to keep it as is, uh, without the need for, um, further, uh, elaborations, thank you. Chair [18:33]: Thank you. Distinguished delegate of Zambia. Okay. Zambia [18:40]: Thank you, Chair, for your leadership, and also thank you for the presentation this morning. It was very elaborate and I think was clarified a lot of things. I would like to echo that Zambia does support the statement delivered by Nigeria on behalf of the African group. And we do concur with Saudi Arabia and India's sentiments as well that the, it does provide, the statement is broad enough and it does recognize the different economic capacities and strength of states. And we do hope that this will definitely show that and prove that international tax cooperation is a reality and it will be possible and it's just not a theory. I thank you. first. Chair [19:36]: The delegate of Jamaica. Jamaica [19:42]: Thank you very much, Chair. Yes, we support the language that is there, given the fact that it's coming from the TOR. I'm just wondering though, are we Going on in the issue note, paragraph 18, it states that the committee is invited to discuss the issue of international tax cooperation approaches that contribute to sustainable development, et cetera. Are we going to be having that discussion during this session? Is it set for another day? And the reason I'm asking that is this. It has been said repeatedly that, and Nigeria just reiterated it and others, that the basis of the work that we are doing is ultimately is to result in us mobilizing domestic resources, achieving the sustainable goals, and to bring about our overall result. that we return to the benefit of particularly developing countries that are struggling with growth and development. And in terms of taxation, and I know there was a FF, the four meeting in Seville and so on, my sense is that there has never really been any clear guidance on how international tax cooperation is to, in a practical way, contribute to the SDGs. And if you look at what countries are doing, and maybe I'll use my own country as an example, the revenue department is focused on tax compliance and revenue collection as it always is. There is a committee that is set up in another institution that is dealing with the sustainable development goals. Both agencies, whereas they may have meetings and so on, there is no clear statement as to how tax is to contribute to that overall outcome. To cut a long story short, I am just wondering whether or not we are going to have a more in-depth discussion on how these various tax cooperation approaches can contribute to sustainable development. I think that would enhance the work that we are doing and I think that it would be a good outcome and good guidance coming out of this meeting as to how the two will relate. Thank you, Chair. Speaker 19 [23:43]: Play all songs of the drama company. Chair [25:12]: So we -- okay, this one is directly off camera. Speaker 21 [25:18]: Okay. Thank you, Chair. I'll start off by endorsing the African group for its position on this particular aspect. However, I have a few observations that I would like to present. We'll start off by, we welcome the committee's focus on integrating sustainable development into the framework convention. However, we believe that it is essential to move from broad-based intentions to targeted commitments that reflect real development priorities, especially for developing countries. In our view, international tax cooperation must do more than align abstractly with the SDGs. It must be purposefully designed to strengthen domestic resource mobilization in ways that directly finance climate adaptation, health systems, and education, which to me are the key pillars to sustainable development in vulnerable countries like ours. We also have to incorporate environmental and social justice objectives in international tax rulemaking, such as addressing harmful tax practices that drain revenues from resource-rich but infrastructure-poor countries. We advocate that sustainable development provisions in the convention include binding commitments to technology transfer and capacity building in tax administrations, fair treatment and global tax norms that does not penalize countries pursuing innovative or redistributive fiscal policies. In short, sustainable development must not remain a rhetoric pillar. It should be a structural priority embedded in the design, implementation, and review of all instruments under this convention. Thank you. Chair [27:25]: Thank you. So now we're moving to multi-stakeholder Tanzania. United Republic of Tanzania · Africa Group [27:37]: Thank you, Chair. The United Republic of Tanzania aligns with the statement made by Nigeria on behalf of the African group. Additionally, Mr. Chair, we full support the recognition of the strong link between international tax cooperation and the achievement of the SDGs. in the three dimensions that is economic, social and environmental in a balanced and integrated manner. Mr. Chair, we state that achieving the SDGs requires a fair allocation of taxing rights that enables all countries, regardless of their level of development, to adequately tax economic activities occurring within their jurisdictions in a table form they may take. In today's globalized and industrialized economy, ensuring such fairness is essential to protect the tax base of all states, particularly developing countries. Mr. Chair, without sufficient, predictable and fairly sourced revenues, our collective aspirations for sustainable development will remain out of reach. Therefore, Mr. Chair, we call support for fair allocation of taxing rights that will ensure additional revenues finance for SDGs. Thank you, Mr. Chair. Chair [28:58]: Thank you. So now we are moving to the multi-stakeholders. So the distinguished representative of International Labor Organization. ILO [29:11]: Thank you so much, Chair, distinguished delegates, dear colleagues. My comments are related to some of the discussion this morning on the role of the UN system, but also this afternoon on the role of taxation and sustainable development. I'll focus my comments today particularly on social protection. I think you all know that expanding social protection is essential for eradicating poverty, reducing inequalities and formalizing employment and enterprises, thus facilitating a just transition to a green economy and promoting gender equality. This recognition was also in the Compromiso de Sevilla, the two percentage point on social protection as agreed language. But despite these efforts, today only 52.4% of the global population is covered by at least one social protection benefit, per the SDG indicator 1.3.1, with 35% of the population covered by contributory social protection mechanisms and 17.3% by non-contributory mechanisms largely financed by taxes. the stagnation of labor income shares, as well as high incidence of informality. The large share of own account workers in many countries and the aging populations pose additional challenges. Hence, contributory systems will not be able to close the social protection financing gap alone. Therefore, there is urgent need to expand access to non-contributory benefit, such as universal pensions, child and family benefits, as well as public health services and/or complement the social security contributions of workers with limited contributory capacity with tax financing. Expanding access to non-contributory social protection financed by taxes not only reduces inequalities and strengthens the social contract but also plays a key role in formalising labour and enterprises. Building on ILO standards and on the FFD4 outcome document, We recommend that the framework convention include a dedicated paragraph which calls for the progressive extension of coverage and social protection systems, including floors, to all, in line with the International Labour Organisation conventions and recommendations, as well as intergovernmentally agreed standards and commitments. This paragraph should also clarify that the social protection coverage extension must be financed through the gradual mobilisation of additional public resources, such as tax revenues and social security contributions generated by implementing the principles set out in the convention for which the current discussions are ongoing. Thank you so much. Chair [31:50]: Thank you. This thing is your representative of Greenpeace. Greenpeace [32:03]: Mr. President, I deliver this statement on behalf of Greenpeace and many civil society organisations working on the issues of tax and sustainable development present here. The truth is we cannot reach the sustainable development goals nor deliver meaningful climate action without fair and effective global tax rules. It was good to hear some parties make comments recognizing this yesterday, although we think that much more ambition is still needed. The global financing gap for climate and development is vast, over 300 billion US dollars annually in climate loss and damages for low-income countries alone. So the UN Framework Convention on Climate Change process is tolling because of this. and countries across board are struggling to find additional resources that would allow them to meet the already agreed financial commitments to address the ongoing climate and ecological crisis. We would like to see a UN tax convention that sends a clear message, those who pollute and profit from climate and nature destruction must contribute the most. This reflects not only a matter of fairness, but also public will. A recent poll across 13 countries representing close to half of the world's population show over 85% of people supporting higher taxes on the super-rich and polluting oil and gas corporations to help increase government spending on sustainable development and climate impacts. On commitments, we recommend the following: One, adopt a sub-commitment under the sustainable development commitment around progressive environmental taxation in line with the polluter pays principle and the principle of common but differentiated responsibilities. This will ensure that those who pollute the most, especially the high net worth individuals and the fossil fuel companies, contribute their fair share and that ordinary households are not unduly burdened with higher tax costs. The convention should include concrete mechanisms such as a tax, a tax on the global profits on fossil fuel companies and other highly polluting sectors, as well as income on polluting assets with revenues to be channeled towards global environmental and sustainable mechanisms. under existing UN arrangements. Secondly, guaranteeing a fairer distribution of taxing rights so that countries where multinational corporations have real economic activities and value and where high net worth individuals generate, hold and shift wealth can secure a just share of tax revenues. So we stand here ready to work together with you, Mr. Chair, and the member states to ensure that this convention delivers for all, especially for the billions of people whose dignity is undermined by tax abuses, climate injustice, environmental degradation, and deepening inequalities. I thank you, Mr. Chair. Chair [35:31]: Thank you. Distinguished representative of Public Service International. PSI [35:40]: Mr. Chairman, delegates, I feel very honored to take the floor here today. I feel honored because of everything that the United Nations stands for. I'm thinking about freedom, justice, and peace. I'm thinking about sustainable development goals, about fundamental rights and gender equality, about stability, prosperity, just to mention a few. And I quote from the Declaration of Human Rights, disregarding them has resulted in barbarous acts which have outraged the conscience of mankind. But for a state without fiscal capacity, these values will be empty words. Fulfilling these commitments, depends upon the ability of the state to mobilize the necessary resources. Today we have a tax system that makes these values hard to uphold for many and almost impossible to uphold for some. Austerity within public services makes itself felt even within my home country, Sweden, where the members of my trade union see big cuts in education, healthcare, social work, and environmental protection. For some states in the global south, compounding legacy of colonialism, this funding has been eroded for decades and more, making it almost impossible for these countries to provide the public services that are taken for granted in high income countries. I would therefore like to add one word to this list of all the above mentioned values, and that word is predictability. We heard it many times yesterday and today, but that was about predictability for companies and predictability for the return of assets and wealth. I must insist that the ultimate predictability is that for every human being and of the sort is of the sort that only the well-functioning and properly funded state can provide, clean water to drink, a living wage, working hospitals and a school for your kids, the protection of democratic liberties and a planet to live upon. We need delegates, a convention that supports this predictability. So we need a convention that explicitly acknowledged the role of tax financing in sustainable development across its three pillars, economic, social and environmental. Delegates, let's make the tax system predictable again. Thank you. Chair [38:33]: Thank you. This thing is representative of major group for children and youth. major group for children and youth · Alexa Dominique [38:42]: Thank you, Chair, for the floor. My name is Alexa Dominique, and I'm a member of the Demond Foundation. I'm speaking on behalf of the FFD Children and Youth Constituency, a major group for children and youth. Chair, sustainable development is a promise made to our generation, and tax justice is essential to fulfill it. If you want the convention to deliver long-term solutions, we must put Agenda 2030 and future generations at the core of the tax. As children, as a children youth constituency, we highlight three main points on the commitment on sustainable development. First, the convention should explicitly recognize intergenerational equity as a foundational principle and its text ensuring the international tax corporation safeguards the rights of future generations. Furthermore, it must be harnessed to drive the reduction of inequality and the promotion of human rights, gender justice and social protection. Second, the convention text must be consistent with the multilateral environmental treaties, we call for the mobilization of domestic public resources generated from the outcomes of the convention to be used as a means of implementation for the agenda 2030 and agenda 2063 and the just transition. Third, in line with the civil commitment and as the LGTQ5 tax systems should be designed to eliminate discriminatory effects on young women and gender diverse youth, including access to SRHR and other essential health commodities. This includes having language in the conventional gender responsive tax and budget analysis frameworks and promoting equal access to benefits from tax funding services. Finally, the pillar of the sustainable development in the UN and the wider UN system processes follows the agenda 21 modalities of the Rio conference. Major groups and other stakeholders, including groups identified in the agenda 21 must be enriched and must be enriched in the tax conventions as the modalities of for stakeholder engagement. We also call upon the tax conventions to have strong synergies and report to the high level of local forum and the broader equal cycle. Chair MGCY is pleased to continue its contributions to the committee. Children and youth believes that these negotiations are directly linked to our future and will continue to advocate for a fair, inclusive and forward-looking international tax system. Thank you. Chair [41:00]: Thank you. Distinguished representative of Monpay Short Accountant Society. [41:09]: Thank you, Chair. My comments is, you know, rather the technical part of it, especially given the words which are used in para 10C. It is recognized that linking sustainable development to tax laws is indeed difficult. When we look at this TOR, there are various aspects of sustainable development under it. What TNC does, it is selecting just three dimensions and saying that this is a commitment. So there are totally how many dimensions are there? Are we saying that the objective is dealing with maybe eight dimensions or ten dimensions and out of that we are committing only for three dimensions? Thank you. Chair [41:56]: Thank you. Distinguished representative of African Union. AU [42:01]: Thank you, Mr. Chair. And the African Union would like to align its submission to the previous interventions of the Africa Group, Zambia, Cameroon, and others. We are committed to global tax systems that not just only correct historical imbalances, but also actively contributes to sustainable development in its own dimension. The UN Framework Convention on International Tax Cooperation provides a historical opportunity to build a new system rooted in equity, transparency, and sovereign right of every nation to raise revenue justly from economic activity within its border. We must seize this moment to create a convention that supports social development in its three dimensions, economic, social and environmental. For Africa, this means ensuring that the new framework convention addresses illicit financial flows and tax avoidance, which strip our continent of the resources needed to invest in health, education and climate resilience. The lack of information on income or assets held abroad is a primary barrier for developing countries in tackling these issues. We urge this committee to develop a comprehensive package of these subjects to ensure a common and comprehensive approach. Furthermore, the fair allocation of taxing rights is paramount. We believe that every jurisdiction where businesses business activity takes place, particularly in our increasingly digitalized economy, should share in the taxing rights over the income generated. This will support domestic mobilization, which is the bedrock of our sustainable development efforts. We call for the convention to explicitly include and undertaking for state parties to establish fair, independent, and accessible dispute prevention and resolution mechanism. A predictable and just system provides the legal certainty needed for cross-border trade and investments, thereby improving domestic resource mobilization. As we move forward, let us remember that the credibility of this process hinged on the ability to create a system that works for all nations, not just for few. The African Union is determined to co-create a framework that is proof, future proof, and genuinely contribute to a more equitable and sustainable world. Thank you. Thank you. Chair [47:23]: So as I, I don't see any more requests for the floor from both sides, member states and the multi-stakeholders. So let us summarize what the outcome of this dialogue that I think what we can get from this that I heard some member states talking about some commitments or some initiatives. that actually will be addressed under other commitments. While some other countries see that the current language as the TOR is very sufficient and is enough to allow for any future things to come under it. So we have two points of view. I think like when we are talking about high net worth individual, I think this is a separate commitment that will come separately under other commitment. Maybe other things like environmental things and gender and other stuff, this goes under sustainable development, which maybe there will be sort of future work on it, then it will cover. So this is the two sides or two conclusions that we get that some commitments will go under sustainable development and some others already will be addressed under other parts of the convention. There is a point of view also that the text should be kept as it is, not to elaborate more in it, so not to lose its holistic view that allow for any future things to go under it. So by this, I think we reach to the end of discussion. And for the distinguished delegate of Kenya. Kenya [49:14]: Thank you, Chair. I just wanted to add my voice to one of the points of view because you've said there are some, I mean, I think different points of view that are arising from comments. And I just wanted to add my voice in support of the comments that were made by Nigeria on behalf of the Africa group. I think when we started these conversations on commitments last year, I used to take the view that commitments need to be as specific as possible so that countries can know what is expected of them. But I think with time and in the context of a framework convention, I understood that the specifics can be taken care of in the protocols, can be addressed in the protocols, and that having a restrictive commitment then restricts the work that can come from that commitment. So I just wanted to support the language that has been proposed that is broad enough to be able to allow for future protocols and a lot of work to come from this commitment. Thank you, thank you, Chair. Chair [50:14]: Thank you. So now, I think by this we end our discussion for the second commitment, which is the sustainable development. And we now can have 10 minutes break, then we come back again to go for the fair allocation of taxing rights, which I believe it will be a hot topic that will take long discussion. So I think so everyone deserves 10 minutes before we start in this hot topic. Thank you. 50. Okay, so now we are back and we, before move to the fair allocation of taxing rights, I just will call back again if there is any one would like to highlight anything related to the sustainable development before we move forward? So, now again, sustainable development, if there is any comments or anything which is remaining or came out from the break, from the discussions between member states, so the floor is opened before we move forward to the next commitment. So, sustainable development again. Thank you, Mr. France [52:04]: Chairman. Indeed, I also wanted to speak in support of the issue raised by Canada. on the addition that was made in the language at the beginning of the sentence. And I think that it's important for States to know very precisely what they're committing to in this wording. It seems to me to be very important to ensure that there's a clarification about the addition, which indeed deviates from what we initially saw. Turning now to sustainable development, here I've also heard interventions by various parties on the desire to translate into practical terms these goals. And, Mr. Chairman, I will take the liberty of providing some elements from France, France which wants to see work go forward on sustainable development in accordance with the goals laid out in the sustainable development goals. We need to strike a delicate balance, one which requires adequate public policies and international cooperation which is strengthened. The first stage to align fiscal principles with the goal of sustainable development is asking questions about how the existing tax system contributes to these goals in a practical sense. With that in mind, France wants to say that the development of green budgeting mechanisms to evaluate the environmental impact of a state's budget by identifying spending that is beneficial or not beneficial to the environment. These tools are particularly important to find out how the tax system can be improved. Also, one must add that in the context of the negotiations of mandates, France proposed the identification of a restricted list of options. These are very concrete options, and particularly in terms of environmental tax, so as to support and finance climate action. France reiterates the proposals that it provided in its last contribution, especially as concerns the taxation of the air segment, the air sector, specifically with regard to international aviation kerosene that's used or a surcharge on airline tickets. Also, there's the introduction of a tax regime on maritime transport. These two sectors are largely not accessed, their tax requiring a large amount of international cooperation to avoid tax havens, which have a major… cross-border nature. Furthermore, we wish to recall that this issue is currently under review in the Working Group on International Solidarity with the aim of finding synergies in other relevant bodies. These thoughts are also found in the work stream on international tax on development and nature, which is established to ensure the low carbon transition. That's particularly the case in vulnerable developing states. This aforementioned working group was launched at the 28th, at the COP28, which was held in Dubai in November 2023, upon the joint initiative of Kenya and France with the support of Spain, Antigua and Barbuda, and Barbados. This initiative responded to the need for new, predictable, adequate financial resources to confront climate change and its consequences, especially as regards loss and damage. So it seems to me to be important to recall these specific initiatives which France is currently enacting. Thank you, Mr. Chairman. Chair [56:52]: Thank you, distinguished delegate of Canada. Canada [56:59]: Thank you, Mr. Chairman. I'd like to thank the delegate from France for coming back to the issue that we raised before the break, notably the addition that was proposed concerning sustainable development. And perhaps I can take this opportunity to go into a bit more detail on what I said earlier. This language was put forward in the issue note as being language that pertains to the discussions on sustainable development and I recognize that most people here are more expert in tax than sustainable development. So I have to admit that the terms used in the preamble which focus on the need to bear in mind the different capacities in different countries, we are just wondering about the interpretation of that language. These are the same goals and principles that were already mentioned in the terms of reference. We're just wondering about the reasons that led to the addition of this wording into the preamble and particularly in this particular context, how should we exactly interpret this language? It is something that we are, this is what we are wondering about. I would be grateful if other delegates would like to chime in on this issue. I know that Colombia has already spoken about it and we're grateful for that, but perhaps if other delegations have anything they would like to say about it because we are unsure about the interpretation of the language in the preamble. If people have a better understanding of the matter than us, then perhaps they could help us to clear these doubts that we have. Thank you very much for listening. Chair [59:37]: Thank you. Thank you, delegate of India. India [59:42]: Thank you, Chair. And thank you to the distinguished delegates of France and Canada to bring up this issue. But we look at this matter slightly differently. Eventually, the commitment that we have made with regard to sustainable development, its actual results will come from the other actions, the other protocols, whether it is in terms of domestic resource mobilisation that will come from the fair allocation of taxes, effective exchange of information, or the practices and measures that we take that will lead to the control of illicit financial flows. All this will provide domestic resource mobilization and will provide access to taxes that will help countries meet their sustainable development goal. So we don't feel that it is necessary to come up with another toolkit of taxation measures specifically under this commitment. This is a commitment that we are making that we tie in our, the work that we are doing with respect to taxation as being related to sustainable development. That is the eventual goal. But the actual taxation measures will come from the other protocols or the other measures that we take. So I don't think that we need to come up with a separate set of taxation measures specifically under this head of sustainable development. Now there has been this discussion about this phrase that has been added which says taking into account different capacities. We understand that this is something that was not there in the terms of reference, but we also must appreciate that The entire discussion that we have had across in the ad hoc committee and thereafter is that our work must take into account the situation of countries who are at different places in the development spectrum. So I don't think it is something to be very concerned if this has been added to the commitment. In fact, I was having a look at the Addis Ababa Action 2030, Resolution 69/313. At paragraphs 27 and more specifically in paragraph 28, there are references of taking into account different capacities of different countries in terms of developmental goals. So if we look at the entirety of the work that we have been doing in this context, I don't think there's a real problem with having this kind of phrase. So that is our thoughts on this matter. Thank you so much. Chair [1:02:34]: Thank you. Distinctive delegate of Nigeria followed by Saudi Arabia. Nigeria · Africa Group [1:02:41]: I thank you very much, Chair. And I also want to Thank colleagues from France and Canada for the issues they have raised and providing opportunity for delegates to respond to those issues. Let me start by saying that Nigeria, we align with the comments from India, but in addition to that, I think it's important we put this issue of taxation and SDG into context. And the context actually starts from the Addis Ababa declaration on domestic revenue mobilization. Of course, we also know the story behind that, which was the need to enable developing countries to actually use revenue generated from within their tax system in a sustainable way to finance development. Now, as to the specific connection, we believe that the framework convention is not the document and the place to begin to elaborate this discussion, but generally we know that Tax is directly related to issue of domestic revenue mobilization. And the ability of states to mobilize domestic revenue depends on a number of factors within the tax system, which includes issues of taxing rights, which includes the issue of ability to have access to timely information by way of exchange of tax information, which includes ability to appropriately and timely dispense with tax disputes. All of these are all banded together to affect the ability of a state to mobilize revenue within its domestic space. Now on the issue of capacity, which again is a key factor within the inability of state to generate domestic revenue, we may want to find out why many developing countries are unable to generate adequate revenue within their domestic space. It has to do with a number of factors, affecting their capacity and capabilities. Not just about technical understanding of tax rules or ability to implement them but there are wider issues of capacity. We are the generally tax rules as constrained developing countries ability to impose tax. That in itself is affecting the capacity. of that state to be able to generate domestic revenue or where the conditions for exchange of information is so encumbering that many developing countries are not able to immediately meet those conditions. Then they are already inhibited from having access to timely information. We're also complexity in rules has such that requires extensive learning, extensive time for people to understand rules, then of course the capacity is constrained. And so when we look at the issue of capacity within this context, it is all-encompassing. There are a lot of things, rules that are in the current systems that are already incapacitating developing countries. those are the issues at stake and mentioned in a very broad way in the paragraph referred to by delegates from France and Canada. Now, what should we do? In my view, the language currently we have works perfectly. Now, elaborating and bringing this into specifics will now have to do with the relevant protocol that may be developed as a consequence of this framework. And so I think this explanation goes to address the issues raised by delegates from France and Canada. Thank you very much, Chair. Chair [1:07:48]: Thank you. Thank you, delegate of Saudi Arabia. Saudi Arabia [1:07:53]: Thank you, Chair. Maybe for the issue of capacity, if we look to the term of reference, specifically maybe paragraph nine, where it says, if I may read it, efforts to achieve the objectives of the framework convention therefore should be universal in approach and scope and should fully consider the different needs, priorities and capacities of countries. So I think this is very well stated in the TOR and I think it is very well clear and what has been put in the language of the amendment made in the language is in line with the term of reference that we have agreed on. Now when it comes to elaboration, I think we have made our position clear that the language as presented on the screen is sufficiently enough and that we are not supposed to go and detail out Um, what sustainable development is, and I don't think we do have the capacity nor the knowledge, um, to do so, and there are other groups within the UN discussing other issues relevant to sustainable development, we are not here supposed to, to address all these issues. And I think we should, you know, respect the mandate of, of, of the other working group that are developing solutions for various issues that are relevant for sustainable development, sustainable development here, as, as many have highlighted, it is a, a principle that we should keep in the back of our head when we develop. the protocols and when we develop the conventions and the rest of the documents. And I think also going and detailing out what sustainable development is, I think we have a list of protocols of paragraphs 16 and 17, which is broad enough to encompass the issues that many of us here in the room might, uh, face or have as a priority, therefore, we reiterate the position that what is, um, in the, uh, what is proposed by the secretariat is sufficient and achieve the purpose, thank you. Chair [1:10:18]: Uh, so, uh, just for Saudi Arabia, the, the paragraph is proposed by the workstream, not the secretariat, okay? So getting back to Canada inquiry, I'm not sure if now the response from other member states satisfies this inquiry. And I think that Sudhir mentioned that we have this capacities as part of the principles in the TIR and now we get Also from the FTD4, it's mentioned there in the part of the language in which those recent international tax cooperation and ensure that international tax rule responds to the diverse needs, priorities, and the capacities of all countries. So it's, I think this language is taken from different sources, T.O.R. and even other forums. So I'm not sure if, if this, but anyway, just, uh, I think to be clear about what we're discussing, we are discussing having this concept of, of, of capacity because now we are not agreeing the text. We will come to the text later on. So that's why just making sure that Canada gets sort of, of some, uh, reflections on, on their inquiry. But anyway, the text, we are not finalizing text right now. Text will be agreed in a later stage in future sessions. So if we are satisfied till this point, I think we can move forward. If there is other points that need to be raised, please let me know. Canada [1:12:57]: Thank you, Mr. Chair. Just very briefly to intervene to thank the other distinguished delegates that have provided very useful information. And for now, we'll think more about it. Thank you. Chair [1:13:15]: Thank you. Distinguished representative of major group of children and youth. major group for children and youth · Muhiriza Allan Muranja [1:13:44]: Thank you, Chair, for the floor. My name is Muhiriza Allan Muranja from Youth for Tax Justice Network that works in over eight countries in the African region. I am speaking on behalf of the major group for children and youth, and we would like to highlight the following priorities. Historically, multinational corporations and high net worth individuals have not paid their fair share of taxes, and this has been because current tax rules majorly allocate taxing rights to countries where whose corporations or persons, or these persons who are usually high net worth individuals are residents. And often these are very few countries and mainly in the global north. By having the allocation of taxing rights under the UN framework convention on tax cooperation. Apologies for that. In the global north, okay. Secondly, countries further committed in the civil commitment where it was agreed that fiscal programming, oh sorry. Chair [1:15:18]: No worries. You can come back again, but we didn't start the discussion about fair allocation, so you can request the floor later on when we start discussing the fair allocation. Which I think we will start now because I think we are done now with the sustainable developments, and now we are going to proceed to discussing the fair allocation rights. Fair tax allocation, right? So before we proceed, I think, do we need Daniel again to brief us about it? So we refresh the minds of everyone? Looks like yes. So Daniel, please just take us back to the presentation, work us through this section. Thank you. Daniel [1:16:17]: Thank you. For fair allocation of taxing rights, we've already related it to one protocol, that's the protocol on services. And we see it as an anchor for that particular protocol. So the commitment basically looks at that, but then expands a bit more on some of these things. Next slide, please. In the discussions, one of the questions was how important this issue of fairness was to each of the states. And we have this one, it was important for supporting domestic revenue mobilization and that currently Taxing rights are being eroded by evolving business models. So there was the need to restore those taxing rights. The other one was to ensure that where business activity occurs, jurisdiction where business should have a share in the taxes that originate from those activities. The question that was, which came out there was, what was the economic basis for allocating such rights? There were quite a number of different ideas on that. One of the things that came out was that the criteria should emphasize economic substance. It should emphasize value creation. And in doing so, we should also look at what impact this would have on trade, investment, efficiency, neutrality, and simplicity. The other thing that was important for members that the rules should be future proof, that they should be adaptable in a way that as business models evolved, taxing rights or taxes would be allocated based on it. interesting because we tried to get into a definition of fairness, which seemed to elude everybody. It was a bit subjective. And so the idea was that as we go on, as we have that discussion amongst ourselves, we'll come out with, if not necessarily a definition, a description or an idea of what we mean by fairness. And that basically will be translated into the protocols. Next slide, please. So the outcome was that the workstream agreed that whatever the commitment we came up with, it should, one, urge all parties to promote, and there should be an approach where all jurisdictions where business activity takes place share in the taxing rights of the related income. And in doing so, we need to have a balance in terms of economic efficiency, tax neutrality, simplicity and the effects they have on cross-border trade and investment. So those were some of the things that came out there. Next slide, please. So that's what led to the questions that we have currently that on the issues we've just discussed or the issues we looked at in the previous slide, whether the elements or the commitments provide a useful outline for a commitment on the topic. So what we looked at, how does they provide the outline, how do you, does it help to define or come out of a text on the commitment. Whether there are any additional concerns regarding fair allocation of tax and rights that should be addressed in the article of that article of the framework convention. So generally that's what we looked at and these are the questions that came out of it which we want to discuss as a group. Thank you. Chair [1:20:30]: Thank you Daniel. So now the floor is opened for comments and interventions on the fair allocation of taxing rights. of Nigeria, followed by India. Nigeria · Africa Group [1:21:36]: Thank you, Chair, and thanks the co-leads for the presentation. I speak on behalf of the African group. And Chair, permit me to start by saying that The global economy itself is rapidly changing. We have the way of doing business depending more and more on digitalization. We see dematerialization happening. We see more and more mobility. of not just people, goods and services, but mobility of profits. And all of these are happening at a pace at which extent tax rules are not able to match. Now, we, the African group, have the view that if we have a framework convention that is not future proof, that is not flexible, and that will not respect sovereign taxing rights of states, then we will have failed in our mission as a committee. And therefore, we believe that this convention and all the protocols that will come underneath it must be able to address existing imbalances in the tax, tax and rights as regard residents and source jurisdictions. And this has nothing to do with whether it is global north or global south. It has to do with where economic activities are happening and the ability of such jurisdictions to bring the revenue or the profits or income to tax in the place where economic activities are happening. So to that extent, Chair, permit me to, on behalf of the African group, make a couple of specific comments, and particularly as related to the questions that are hashed. As to whether the elements in relevant paragraph provides useful outline of commitment on fair allocation of taxing rights, we must first of all commend the chair and the co-leads and the team for the intent because the intent is very clear, which is to provide a level playing ground for all states. However, the African group, we are concerned that beginning to put detailed explanations, criterias, definitions within the body of the framework convention is not properly situated. In our view, the convention should avoid detailing how or where business activity takes place or attempting to define case subtext such as fair allocation at this stage because we believe doing so would divert our attention to begin to look, take ourselves away from the real issue and then we may be chasing shadows. We think that having a general reference as we, it reflects, it reflective of what we have in the terms of reference saying parties commit to the fair allocation of thousand rights including the equitable utilization of multinational enterprises should survive because that's a very simple language, simple sentence that everyone can relate with and therefore we should be careful that our formulation do not begin to go into micro issues. The second point, Chair, is if there are concerns regarding taxation right that should be addressed in the framework. Yes, there are, but with qualifications. If any specific element are referenced in this commitment, it is ensured that they be presented as indicative and not exhaustive, and I think that is also a major issue there. So we do not expect that the items or the issues will be exhaustive because we cannot sit here in 2025 and see into what happens in 2030 or 2040 and be able to 100% sure and begin to list. So we should be careful to ensure that such items mentioned or listed listing them should be indicative. I think in final comments, Chair, we believe that whatever we are doing, we must look at fair allocation of taxing rights to include rebalancing taxing rights in the digital economy. We should also look at the issue of value creation and we believe this is very critical, particularly for source countries. And also we should be able to have a statement that safeguards the right of source jurisdiction to tax economic activities based on their domestic rules. These are the elements that we hope we will find in the final text of the framework convention. Chair, thank you for indulging me. God bless. Chair [1:28:12]: Thank you. Thank you, delegate of India. India [1:28:17]: Thank you, Chair. And our comments would be something in line with what has just been said by the distinguished delegate from Nigeria. In fact, as they say in English, that if you don't have time to write a short letter, you write a long letter. So, we began the commitment with a very short statement, that fair allocation of taxation rights, including equitable taxation of multinational enterprises. That was all. And now we have at paragraph 14 a very, very huge paragraph. I don't think that there is merit in trying to say too much because as the distinguished delegate from Nigeria pointed out, the business models are evolving and the issues that are at play here are very dynamic. So if we kind of try to over explain ourselves or try to use language that is not general enough, then we may not be able to deal with situations that will arise in the future. So therefore, we should not try to, we believe that we should not try to tie down this commitment in too much explanation and too much of words and phrases. And over the past year and a half that we have been doing this work, there are certain phrases that we have agreed upon. We've agreed upon phrases like where economic activity occurs, value is created, or where revenues are generated. So I think we should stick to language that we have more or less agreed upon, where we understand the context, we understand the meaning. Now, if we try to use something new, like business activity, then I think we are opening another round of discussion, another round of trying to understand what this thing, what it means. So, and then we have gone on to say over here, we've talked of economic efficiency, tax neutrality, simplicity, administrability. I mean, there are so many words, each of which will have different meanings. And eventually, that second part of that paragraph actually belongs to the principles section. And here we are talking about commitments. So our commitment should be, the language that we use in our commitment should be crisp, It should be in terms of language that will serve us in the future and phrases which we understand. If we just simply say that parties to the convention agree to a fair allocation of taxing rights, recognizing that every jurisdiction should share the taxing rights depending where economic activity occurs, value is created, and from where revenues are generated, I think that would suffice. And we need not have too much explanation, too many words, too many phrases. and then come to grief later. So that is something that first comes to mind. And yes, as the distinguished delegate from Nigeria said, that it should be future proof. In fact, that's what is written in paragraph 12. So I think that is something that we should keep in mind when we go on with this work. Thank you. Russian Federation [1:31:45]: Mr. Chairman, distinguished colleagues, thank you for giving me the floor. In addition to some general remarks, that were voiced by the distinguished delegates from Nigeria and India, we in turn would like to propose a number of very practical suggestions regarding the drafting of certain points. In the section on the fair allocation of taxing rights, the issue note of workstream one proposes comment on two issues. In this regard, both of the issues about the usefulness of the commitment on fair taxing allocation and on the additional concerns that should be reflected, these two issues are interrelated. That's why we would like to note that the provisions of paragraph 14, in our view, do not sufficiently reflect the commitments under this issue and they do not fully correspond with the position laid out in the issue note of workstream 2. Given this fact, a description of this commitment needs to be clarified and specified in the following areas. Paragraph 14 contains the following sentence: that there might also be need, there might also need to be some explanation of how to determine where business activity takes place in light of digitalization and other business models. In our view, this, uh, phrase, where business activity takes place is essential and it needs to be qualified in detail or it might need to be clarified. We think that this phrase in its current form brings us closest to the existing taxation system, which is based on the concept of permanent establishment. I don't think that this was our intent, neither in workstream one nor in workstream number two. Furthermore, the descriptive section on the fair taxation of services that was raised by various participants in the workstream failed to reflect, in our view, a key aspect that was mentioned as a key factor by many participants, a key factor in blocking the fair Allocation of taxation rights, I'm referring to the restriction of, uh, taxation rights set out in double tax, uh, treaties. Many delegations noted that double tax, uh, agreements in the current form in which they currently, uh, uh, act are that restrict the tax rights of source countries. So we would propose adding in paragraph 12 of the issues paper some provisions that address this concern. We also think that there is a need to address the source taxation. This issue is relevant in with regard to the optional nature of the protocols and the need to create the convention as a tool to address practical tasks, Russia stands ready to support the concept of holding mechanism. It could be similar to the mechanism withholding tax on services set out in Article 12AA of the UN Model Convention. Thank you. Chair [1:36:09]: Thank you. So I don't see any more requests from member states, so we go for more stakeholders. Distinguished representative of ICR ICT. ICRICT [1:36:37]: Distinguished chairman, distinguished delegates, a fair allocation of tax rights necessarily involves reforming the current international tax system and the principles that currently exist and are applied and the rules that currently underpin the international tax system are unfair as they do not take into account the income generated in countries where the income is generated. This system currently has allowed multinational companies to erode the tax base in all countries, both developed and developing countries. This has only boosted their profits but has been unfair to many countries. Given that countries in the global South are more dependent on tax receipts, this has only exacerbated inequality between countries and it has prevented countries in the global South from achieving sustainable development. The current rules are also unfair because they put multinationals at an advantage in comparison with smaller national companies. Entities operating throughout the world are able to benefit from the current rules, which are fundamentally unfair. Tax administrations are not able to collect resources adequately. Therefore, we need to have a root and branch reform of the current system and we need to understand ultimately that multinational companies highly integrated and have one group of owners, and that is where we need to move beyond the current way in which we perceive multinationals and ensure that they are appropriately taxed at a fair level. The principle of full competence that exists at the moment allows multinational companies to play the system and prevents them from being fairly taxed at source. This is something that is to the detriment particularly of countries in the global south. The concept of a physical presence being required is something that we need to move beyond from because it clearly doesn't apply in the current highly digitalized economy that we now live in. Companies can operate in a country without necessarily being physically present there. That is the reality today and that is what we need to bear in mind. in adopting the current rules and that is why the future convention must ensure the equitable taxation of multinational companies bearing these clear facts in mind looking at real economic activity and real profits that are being generated this is how we should move forward thank you Chair [1:40:15]: Thank you. Distinguished representative of Tax Justice Network. TJN [1:40:22]: Thank you, Mr. Chair, distinguished delegates. Taxation is always, at the national or international level, a pact. It requires cooperation either by citizens and their governments or even, as we are discussing here, between countries. Yet countries and citizens are not indifferent to how the benefits and the burdens of cooperations are going to be distributed. Fairness here is super important because it is the basis of this pact. A fair allocation of taxing rights is crucial to establish the legitimacy of this instrument we are discussing. And we should recognize that the unfairness of current rules is, as raised by many others, one of the drivers of this process. To understand the meaning of fairness, we need to read the convention as a whole and particularly to understand the commitments in clear relationship to the principles and objectives which are already included in the TORs. In general, we consider that the principles and objectives provide an adequate guidance on how the concept of fairness should be understood, that it should further sustainable development and should contribute to the fulfillment of social, economic and cultural rights. To fulfill these objectives and to be aligned with these principles, it is also important to note that the limitations my colleague referred to tax treaties in relation to multinational enterprises in regards to taxation at source are also applicable in the case of personal income and wealth taxes. Many tax treaties limit the possibility of extending tax residency or applying exit taxes to individuals, in a world in which there is a growing tendency for some jurisdictions to offer tax residency for high-net-worth individuals with tax benefits in exchange for investment. In addition, the bias on residency is all the more problematic in a context where the wealth and income of the millionaires and billionaires are not only domestically sourced, but often have a cross-border nature. This is critical for the committee to consider as the commitment speaks about the allocation of taxing rights, including but not limited to the taxation of multinationals. Therefore, while there is a specific commitment on the topic, we want to know that the fair allocation of taxing rights should also provide a basis for a coordinated approach to the taxation of high net worth individuals. Such coordination is important to address global tax regressivity and enable countries to raise revenues effectively and to effectively tax this group. The compromise establishes a fair commitment for member states to promote progressivity and efficiency across fiscal systems. and to address inequality and increase revenue. The aim of reducing inequality within and between countries should be a key component of what fairness means. This is a critical consideration both for this commitment as well for the one addressing tax evasion and avoidance by high net worth individuals and ensuring their effective taxation in relevant member states. Moreover, we also call for to unpack some of these commitments so that they can be actionable through the ABC of tax transparency. The fair allocation of taxing rights goes hand in hand with the need to better access of data by authorities and also to have better mechanisms to exchange this information. This has clear implications for the taxation of multinational companies and high net worth individuals. We believe here that a global register of assets, as well as a common public database of country by country reports, is crucial to deliver this commitment. Thank you very much, Mr. Chair. Chair [1:44:01]: Thank you, distinguished representative of ATAF. ATAF [1:44:07]: Thank you, Chair, for giving ATAF the floor. We want to emphasize first by pointing out that fair allocation of taxing rights is like a thread that runs across every aspect of this work. But before we do that, we want to align completely with the statement given by Nigeria on behalf of the African group, and also identify with the statement issued by India in this respect. Fair allocation of taxing rights is as important as you can get when you talk about this work. And we have spoken about how do we come to a language that we capture both present and future use of this particular commitment. So what's like broad principle-based flexibility has been thrown about. And fortunately, we go back to the terms of reference. The terms of reference have given us clear indication as to how best to frame this commitment. you go to paragraph 10 of terms of reference, it's very clear. I think just in line with comment made by India that we should build on that paragraph 10 provisions in crafting our commitment language in the commitment section of the framework convention. When you go to protocol two, protocol one on cross-border services, it becomes entirely a more detailed approach. Because in that context, we are now talking about how do parties relate to the substantive tax rule that we develop as to whether they have fairly allocated taxing right between them. So for some countries, development of new taxing nexus will solve the purposes of equitable allocation of taxing right. For others, it may be ensuring that withholding taxes when they apply to services in market jurisdiction is not excessive. So you begin to see that these terms could assume different meaning to different people in respect of different work streams. And like colleague who just spoke pointed out, it shouldn't just be tied to cross-border services alone. It can be in the context of rejigging or reviewing the tax treaty rules. as it were, if there is a future protocol to deal with that. It can also be in the context of taxation on multinational enterprises. There is no limit to where this particular commitment can apply. So to that extent, ARTAF supports a language that is closely tied to the already agreed language in the terms of reference. And we believe that in the context of the framework convention, we do not need to be definitive or more elaborate than those languages as contained in the terms of reference. We thank you, Chair. Chair [1:47:17]: Thank you. Distinguished representative of Mumbai Chartered Accountants Society. [1:47:26]: Thank you, Chair. My comment is on para 14 of the note. This is giving taxing rights to the jurisdiction where the business activities take place. Now whether consumption is to be seen as a business activity for this purpose is not clear. A better approach could be to also refer to the place or the jurisdiction where the end consumer is located for the purpose of allocation of taxing rights. Thank you. Chair [1:47:57]: Thank you, distinguished representative of Youth for Tax Justice Network. major group for children and youth · Arpan [1:48:05]: Uh, thank you, Chair, for the floor. My name is Arpan, and I'm speaking on behalf of the FFD Children and Youth Constituency from the Major Group for Children and Youth. We apologize for the technical issues earlier as we are navigating various Google documents. As children and youth constituency, we want to highlight the following priorities. First, historically multinational corporations and high net worth individuals have not paid their fair share of tax. This is because current international tax rules majorly allocate taxing rights to countries where these corporations or persons are resident, often in the few countries mainly in the global north that are responsible for creation of these rules. On the commitment on fair allocation of taxing rights, we call upon states to consider a minimum corporate tax rate that would allow for the fair taxation of multinational enterprises and ensure that invasive strategies like profit shifting can be properly restricted. Second, we call for the removal of the failed transfer pricing approach, which allows corporate entities to utilize differences in national tax systems to compromise critical domestic public resource utilization for Agenda 2030 and social safety nets. We urge the committee to consider multinational enterprises as a singular entity, basing their corporate taxes on global and not national income. Tax policy is not neutral. It is a choice about whose future is being financed and whose future is being drained for private gain. We call on the committee to move beyond half measures and partial fixes and instead commit to a tax system that delivers justice, across borders and across generations. I thank you. Chair [1:49:50]: Thank you. I think we are left with around 30 minutes in the time of this session and then we need to close. So I will propose that we end the session at this point because I think this topic still needs a lot of of discussions and to start tomorrow morning with fresh minds to explore this topic better. So by this we have concluded, the committee has concluded its work program for this afternoon and we're going to convene again tomorrow at 10 a.m. in the same room. Have a nice evening and looking forward to see you all tomorrow. The meeting adjourned. So