(1st meeting) - Fifth Session of the Intergovernmental Negotiating Committee on the UN Framework Convention on International Tax Cooperation (INC Tax) - 3 to 13 August 2026

Excellencies, distinguished delegates, good morning. I declare open the 5th session of the Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation and call its first plenary meeting To order. I will now deliver an opening statement. Excellencies, distinguished delegates, dear colleagues, I welcome you to the first session— to the 5th session of the Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation. Cooperation and its 2 early protocols. It's a pleasure to welcome you back to New York as we begin the 2nd substantive session of our work in 2026. This session marks an important transition in the work of the committee. Since we began our substantive work last year, the 3 work streams have advanced through successive stages of discussion, technical consideration, and drafting. For the first time, the Committee has before it draft texts covering all 3 instruments. This is a significant step forward. It means that we can now move from discussing concepts and possible approaches to examining concrete provisions. Having the 3 texts before us also allows the Committee to consider how they fit together. We can examine how the objectives, principles, and commitments of the Framework Convention relate to the more specific provisions of the protocols. We can consider whether terminologies, procedures are appropriately aligned, whether there are gaps or unnecessary overlaps, and whether particular provisions have been placed in the instrument where they can operate most effectively. Our task during this session is therefore not only to consider the substance of each instrument individually, but also to assess the adequacy of their provisions and their interactions. Excellencies, it is important to be clear about the nature of the documents before us. These are zero drafts. They are working texts intended to give concrete form to our discussions and to provide a basis on which negotiations can begin. Where alternative formulations appear, The committee will need to consider which approach should be pursued. Where language is placed in square brackets, this indicates an issue on which further direction from member states is required. Where delegations consider that the language should be amended, strengthened, qualified, reallocated, or removed, this is the stage at which those views. Should be presented. A provision in a zero draft doesn't— does not mean that the matter has been settled. Similarly, the absence of a proposal from the current text does not prevent the committee from considering it. During this session, the committee will begin its provision-by-provision consideration of the text. Our immediate purpose is to identify where there is this support for the approaches reflected in the drafts, understand the concerns and alternatives raised by delegations, and provide the co-leads with sufficiently clear direction to prepare the next versions. Throughout this process, proposals will need to receive sufficient support from the floor in order to be carried forward in subsequent drafts. There is much to do between now and the Nairobi session and not much time to do it. Therefore, to make effective use of our limited time, I encourage delegations to focus their interventions directly on the provisions under consideration, explain the reasons for any proposed changes, and wherever possible, offer concrete alternatives. I also encourage delegations to consider the implications of their proposals for other provisions and for the coherence of the 3 instruments as a whole. I will work with the Bureau, the co-leads, and the Secretariat to keep our discussions focused and efficient while ensuring that every delegation has a meaningful opportunity to participate. As in previous sessions, the allocation of time among the Framework Convention and the 2 Protocols may need to be adjusted depending on the progress of our discussions. Excellencies, the drafts before us reflect the substantial work undertaken by the delegations, the co-leads, and the Secretariat since the Committee began its substantive work last year. They are a product of a cumulative process, but they are not its conclusion. They are the start— the starting point for the next and more detailed phase of our negotiation. As always, our work must remain inclusive, transparent, and member-state-led. Every delegation must have a meaningful opportunity to contribute, and progress will require careful listening, flexibility, and mutual respect. The engagement of stakeholders from international organizations, civil society, academia, and the private sector also continues to enrich our work and encourage them to contribute constructively. Before we begin, I wish to express my appreciation to our co-leads for their leadership, to the Secretariat for their— for its tireless support, to stakeholders for their constructive engagement, and to all delegations for the work undertaken in the preparation for this session. With that, let's begin our work. Thank you. I now give the floor to Ms. Björk Sandgren, Assistant Secretary-General for Policy Coordination in the Department of Economic and Social Affairs. The floor is yours.

Thank you very much, Chair, and good morning, Excellencies, distinguished delegates. And colleagues. It is indeed a great pleasure to welcome you to this 5th session of the Intergovernmental Negotiation Committee on a United Nations Framework Convention on International Tax Cooperation. Also, on behalf of the Under-Secretary-General of DESA, Mr. Lee Jun-hwa, let me begin by thanking the Chair, the Bureau, the co-leads, delegations, and all those who have contributed to the intense work undertaken since the Committee last met. The documents that we have before us this morning reflect sustained engagement and careful technical and legal work. This commitment speaks to the seriousness with which member states continue to approach this process. Dear colleagues, let me highlight 3 messages at the outset of this week's meeting. First, on the significance of this moment, these negotiations serve a larger purpose because international tax cooperation is not an end in itself. It's about enabling countries to mobilize domestic resources for sustainable development, to reduce inequality and invest in people. It's also about ensuring that the international tax system reflects the sovereign equality of all member states and that all countries can participate meaningfully in shaping the rules that affect them. This. Is a historic opportunity to build a system that is more inclusive, fair, transparent, and effective, and that responds to the different needs, priorities, and capacities of countries. My second message, on the progress achieved. The Committee now has before it drafts of the Framework Convention and both of the early Protocols. At the 4th session, We spoke of 2026 as the year in which the process would move from scoping to drafting, and that transition has now taken place. The draft convention sets out proposed principles, commitments, and institutional arrangements. The 2 draft protocols address taxation of income from cross-border services and the prevention and resolution of tax disputes. Taken together, these texts provide a concrete basis for the negotiations that lie ahead. Their preparation reflects substantial progress, as well as contributions and different perspectives presented by Member States throughout the negotiations during the intersessional work. My third message on the work ahead. The circulation of these drafts is clearly not the conclusion of the process. It really marks the beginning of maybe the most demanding phase, the negotiation of the texts themselves. I'm sure, delegations, you are fully aware of how you now need to examine the language carefully, identify areas of convergence, and address differences constructively. The task is to translate shared objectives into provisions that are clear, balanced, administrable, and capable of effective implementation. This will require technical rigor and political judgment. It will also require flexibility, patience, and a willingness to listen. International tax cooperation goes to the heart of national sovereignty and development priorities, so I think differences are therefore natural, but our collective responsibility is to work through them in a manner that is open, inclusive, transparent, and grounded in mutual respect. The strength and legitimacy of the Convention will depend not only on the substance of the final texts, but also on the integrity of the process through which they are negotiated. On our part, as the UN Secretariat, we will continue to support this member-state-led process in an impartial and transparent manner and provide the support necessary for all delegations to participate. effectively. So, ladies and gentlemen, with that, I will now hand the floor back to the Chair, who will guide the Committee through the organization of work as well as the issues before you over the coming 2 weeks. Thank you.

I thank the Assistant Secretary-General. The Committee will resume its consideration of Agenda Item One entitled Election of Officers. In accordance with the General Assembly Resolution 79235 of 24th of December 2024, the committee chair elects 18 vice chairs and a rapporteur elected on the basis of equitable geographical representation and taking into account gender balance. I have received the following resignations from among the African states. Mr. Matthew Jabunjola of Nigeria, from among ASEAN-specific states, Mr. Kualong Li of China, Mr. Bhaskar Joswami of India, and Mr. Wusail Al-Malki of Saudi Arabia, and Ms. Ya Fan of Singapore. From among the Eastern European states, Mr. Lukáš Hrdlička of Czech Republic. From among Western Europe and other states, Ms. Sara Groh of Denmark and Ms. Angela Wölfers of Sweden. I have received the following nominations. From among African states, Mr. Sunday Okiowo of Nigeria. From among the Asia-specific states, Mr. Kwang-gook Byun of Republic of Korea, Mr. Abbas Tajik of Islamic Republic of Iran, Mr. Fida Muhammad of Pakistan, and Ms. Asmaa El-Zarouni of United Arab Emirates. From among the Eastern European states, Ms. Zsógi Antall of Hungary. From among Western Europe and other states, Ms. Angie Klooschert of Belgium and Ms. Márcia Oro of Portugal. So excuse me for any wrong pronunciation for any of these names. May I take it that the committee wishes to elect the nominees by by acclamation as vice chairs of the committee? I hear no objection. It is so decided. On behalf of the committee, I congratulate the vice chairs. The committee has thus concluded this stage of its consideration of agenda item 1. The committee will resume its consideration of of Agenda Item 3 entitled Organizational Matters. Members will recall that by its Decision 2 taken on the 3rd of— Decision 2 taken on the 3rd of February 2025, the committee adopted the program of work for its sessions on the understanding that it might be revised during the sessions as needed. In this connection, the revised program of work is contained in document CRB 31, which has been distributed to delegations via e-delegate and the website. Members will also recall that by its decision 3 taken on the, on 6th of February 2025, the committee decided to take decisions at the beginning of each of its sessions on any new applications by international organizations and on participation of representatives of other relevant non-governmental organizations, civil society organizations, academic institutions, the private sectors— the private sector, and other stakeholders. In this connection, the committee has before it draft decision CRB 30 entitled Participation of International Organizations, Civil Society, and Other Relevant Stakeholders in I now give the floor to the representative of Ireland to introduce draft amendment CRB35.

Thank you, Mr. Chair. Is that on? Yeah, that is perfect. Uh, thank you, Mr. Chair. Uh, through the document titled List of Applications from Civil Society Organizations and Other Relevant Stakeholders to Participate in INC Tax, shared on 10 April 2026, the Secretariat provided information on applications for accreditation from intergovernmental organizations, civil society organizations, academic institutions, private sector organizations, and other relevant stakeholders. In the draft decision of 3 June 2026, contained in document A/AC.298/CRP.30, 2 non-governmental organizations included in the April 10th document are not listed among stakeholder— stakeholders proposed for admission. Based on the available documentation, It is not clear whether objections were raised, and if so, how they were substantiated, nor is it apparent by whom the objections were raised. Against this background, the reasons for their exclusion remain unclear. Ireland is committed to ensuring the inclusivity and transparency of the work of the INC. In this context, we strongly support inclusive and meaningful multi-stakeholder engagement. Guided by these considerations, Ireland advocates for the extension of the list of admitted stakeholders to include the 2 non-governmental organizations concerned. The amendment submitted by Ireland serves this objective. Thank you.

Thank you. I now give the floor to the Secretary.

Thank you, Chair, and good morning, Excellencies, distinguished delegates. If any countries not listed on CRP 35 wish to co-sponsor The draft amendment submitted by Ireland, please press the microphone button now. I see Canada, Bulgaria, Greece, Lithuania, Switzerland, Austria. Finland. Belgium. Estonia. Luxembourg. Norway. Portugal. Germany. Poland. Denmark. The Kingdom of the Netherlands. France. Slovakia. Slovenia, Croatia, Sweden, Czechia, and Spain. If these delegations could kindly unpress the microphone button. If there are any further delegations not listed on CRP 35, which I have not read out just now, who wish to co-sponsor the draft amendment submitted by Ireland, please press the microphone button. I see Latvia. Malta, Italy, and then that concludes the list. Thank you, Mr. Chair. Mr. Chair, I recognize Hungary as a co-sponsor of the draft amendment. Thank you, Mr. Chair.

I thank the Secretary. I now give the floor to the representative of Turkey on, on a point of order.

Thank you, Mr. Chair. My delegation requests that the draft amendment CRP.35 be divided so that the 2 organizations listed therein are considered separately. We further request a recorded vote on the second part of the amendment concerning the participation of the organization called Kenya Human Rights Commission. I thank you.

I thank the representative of Turkey. I understand that the representative of Turkey has moved with the meaning of rule 129, that a separate recorded vote to be taken on the inclusion of the organization entitled Kenya Human Rights Commission as listed in the draft amendment CRB 35. May I ask the representative of Turkey to confirm this understanding?

That is correct, yes.

Are you saying the representative of Turkey? May I take it that the committee wishes to proceed accordingly? I see no objection. It is so decided. Delegations wishing to make a statement in the explanation of vote before the vote on any or all of the proposals under this item, including the draft and the draft amendment are invited to do so now in one intervention. After action on all of them, there will be an opportunity to— for explanation of vote after the vote on any or all of them. I remind delegations that the statement in explanation of vote are limited to 5 minutes. Distinguished delegate of Turkey, the floor is yours.

Thank you, Mr. Chair. Turkey will vote against the part of the amendment CRP.35 concerning the organization called Kenya Human Rights Commission. The Kenya Human Rights Commission has been the subject of serious allegations by competent authorities of the state in which it is established, including allegations of operating unauthorized bank accounts, failing to comply with tax obligations, and employing foreign personnel without permission. While subsequent judicial proceedings identified procedural deficiencies in the actions taken by those authorities, the Court did not determine the merits of those allegations. In our view, such unresolved concerns warrant caution when considering the organization's participation in UN meetings. We also regret that no delegation engaged with Türkiye bilaterally to discuss our concerns or to seek a mutually acceptable solution regarding the inclusion of this organization. We would have welcomed such an exchange in good faith and remained ready to work constructively towards a consensual outcome. In the absence of such engagement, we have no choice but to oppose the inclusion of the Kenya Human Rights Commission and therefore call upon all member states to vote against the part of the amendment CRP.35 concerning that organization. I thank you.

We have heard the last speaker in explanation of vote before the vote. We will now proceed to consider draft decision CRP 30 and draft amendment CRP 35. Before we take action on the draft decision, in accordance with Rule 130 of the Rules of Procedure, the committee shall first take a decision on the draft amendment CRP 35. In accordance with the decision taken just now, we will now proceed to consider the inclusion of the organization entitled Kenya Human Rights Commission. A recorded vote has been requested. We shall now begin the vote process. Those in favor of inclusion— including the organization entitled Kenya Human Rights Commission, Please signify those against abstentions. The Committee is now voting on the inclusion of the organization Kenya Human Rights Commission. A vote yes signifies a vote in favor of including the organization Kenya Human Rights Commission. A vote no signifies a vote against including the organization Kenya Human Rights Commission. Will all delegations confirm that their votes are accurately reflected on the screen? The voting has been completed. Please lock the machine. The result of the vote is as follows: in favour, 42; against, 3; abstentions, 20. The Committee has decided to include the organization entitled the Human Rights— Kenya Human Rights Commission. May I, may I take it that the Committee wishes to adopt draft amendment CRP 35 as a whole? I hear no objection. It is so decided. The committee will now proceed to consider draft decision CRB 30 as amended. May I take it that the committee wishes to adopt draft decision CRB 30 as amended? I hear no objection. It is so decided. The committee has thus concluded this stage of its consideration of agenda item 3. Before adjourning the meeting, I would like to advise that immediately after this meeting, the committee will hold an informal meeting. The meeting is adjourned.

Congratulations, Mr. Chair. Hold on. Delegates, dear delegates, we are gonna start the informal meeting just in 5 minutes from now. We're just doing do some changes to the podium and we'll start in 5 minutes. So I recommend if you can stay and keep in your place. Thank you.

Thank you. Distinguished delegates, we will now begin our informal meeting and our consideration of Workstream 1 on the United Nations Framework Convention on International Tax cooperation. The committee will now have before it the co-lead zero draft of the framework convention, which includes both the articles discussed in previous sessions and newly proposed articles, presenting for the first time a complete draft of the convention. The text brings together the objectives and principles of the convention, its general commitments, provisions on technical assistance and capacity building institutional arrangements, and the final provisions. It also seeks to establish a coherent relationship between these different parts and between the Framework Convention and the protocols that may implement or future elaborate its commitments. Our task during these informal discussions is therefore to examine the text article by article. Identify areas of convention and provide clear guidance on the issues that may require further work. I would like to thank Daniel, co-lead of Workstream 1, as well as the Secretariat for the considerable work undertaken in preparing, in preparing the zero draft. I will now hand over to Daniel to introduce the text and guide us through the first group of articles. Mr. Daniel, the floor is yours. Thank you,

Mr. Good morning, delegates and distinguished excellencies, and thank you, Chairman, for the introduction. It's good to see everybody again, and as The Chairman has mentioned, basically over the past few months since February, we've been working on putting together a zero draft for discussion through the intersessional meetings. We basically have reflected, um, as we understood the inputs that we've received. Now, as we move into these discussions, I think it would be good for us to just do a quick recap and refresh our memory on some of the things we've gone through over the period. And since I'm sure a few of us are here for the first time, through the development of the Terms of Reference in 2024, where we came out with what we expect this committee to undertake and the work we've done so far. Last year, where we spent scoping the various items in the work streams, the Framework Convention and the first 2 protocols. Now, this year, we've started with the takeout drafting and I believe that we are all happy we've received a zero draft to discuss. And if I may go the way of— locally, we like using proverbs a lot. There's an Igbo proverb, a saying that says that the lizard who jumped from the great iruku tree to the ground said that if men will not praise him, he'll praise himself. Yes. So I think we can all give ourselves a pat on the back for at least what we've been able to do so far and how far we've gone to. And as we continue, I think we all agree that there's been a lot of technicalities, there's a lot of complexity, but we've been able to get this far. And so I wish to encourage all of us as we continue that the Chair has already mentioned that what we need to do at this I miss, look at this zero draft, see what additional inputs, what we need to take out. And I would urge all of us as we go along to also look at what are the concerns we have and suggest what we can use to address those concerns, not just the concerns in a vacuum, because then we'll make very good use of our time and be able to actually work on the document. Thank you. As we all know, this is a member state-led document. It's what member states say that must reflect in the document. So if there's something that doesn't seem to jive with all of us, we need to work on it while looking at the interests of everybody. So what we've done with the zero draft is we've sort of grouped them. Initially, we've just been working on them, but we've now grouped them into several parts, 5 parts, if we'll put it that way. Yeah. We've come out with an introduction which basically takes the first 3 articles, that's the objectives, principles, and definitions. We've created a part 2, which is the general provisions, so it looks at the what we are calling commitments, if I should put it that way, but then they are just general resolutions or provisions as we've put them. All the items we looked at over there, we've looked at technical assistance, which is in Article 12. Article 13 to 18 looks at the institutional arrangements, the Conference of Parties, subsidiary bodies, Data collection and analysis, review and verification, secretariat, and financial resources. Then we have the final provisions. We looked at amendments, relationship with protocols, relationship with other agreements and domestic law. We looked at settlement of disputes, the signature and ratification and entry into force, reservations, and withdrawals. So generally, this is the way we've put the— we've drafted the Framework Convention, and these headings are just to help us to group them and have meaningful discussions. So the zero draft, okay, is built basically around these 3 cross-cutting approaches. One, we've looked at the objectives and principles and their commitments which basically establish the Convention. Then, as we discussed previously, the actual rules for— will then be developed through the protocols. There's a remit for periodic reviews and amendments that allow the framework to respond to new challenges. We've always said that we want to put in a system that is future-proof and will be flexible enough to adapt to future changes. The governance structure, too, again, is we looked at the Conference of Parties, which provides political and legal direction. We looked at subsidiary bodies that will support implementation, and then any other bodies that will be given specific tasks as we will all agree from time to time. Then the third part looks at implementation as part of the design. I mean, we can have a very good document, but if we don't implement it, then basically we spent about 3 or 4 years doing nothing. And so we look at the implementation part, we look at capacity building and technical assistance, and also we've looked at data, how we review and verify and support the implementation. We've also looked at what financial resources will be required, and all of these things are things that we need to look at, especially in the case of developing countries and others who need additional assistance in order to get some of these things done. So generally, these are the cross-cutting issues that we've looked at. These are the things that the document revolves around, and These are the things that we need to have at the back of our minds as we continue our discussions. And so, in looking at the governance structure, I think I want to go a bit into it because basically the governance structure is what would sit between our work as the INC and the future of the Convention itself. And so for the Conference of Parties, we've looked at how it should be established and how it will help to achieve the objectives of the Convention. We've looked at its function in terms of adopting rules and of course elaborating and adopting the supplementary We've also looked at how the COP can establish additional bodies, workgroups, task forces, and whatever to get the implication done. And then also what other technical assistance and capacity building will be required to carry out and implement the convention. We've also proposed a subsidiary body for implementation, which basically will sit between the COP COP and the actual work that needs to be done. It is a body that per UN rules will be open to all parties, all state parties. It won't be limited to anybody. It will be basically government representatives, hopefully more of technical experts. And then it will assist the COP in implementing the convention. It will report to the COP. Periodically provide recommendations that will help with implementation. There is the provision, as I mentioned earlier, for additional bodies, and they can be temporary or they can be permanent depending on what we agree. They'll be there for specific tasks to undertake research or to provide some ongoing advice on items that as and when it is required. And they will also report to the COP or to the subsidiary body for implementation, as we will all determine. Then finally, we have the Secretariat, which will be required to support the sessions and the reporting and implementation activities. It will also assist State Parties in providing information to the conference and will coordinate with the relevant international and regional organizations and other stakeholders that will be required for implementation of the Convention. So generally, these are some of the things we want to talk about as introductory remarks, and as I mentioned again, And the chair has mentioned several times, these are just preliminary discussions. They are not cast in stone. They are open to each of us to contribute to, to add, to amend, to comment as we deem fit, so that together we can come out with a framework convention that will stand the test of time, that will meet the needs of all member states and will support international task cooperation. Thank you. Um, yeah, thank you. That's the end of the initial presentation. Give me a minute, we'll move into the articles. We will now move to the text as we have shared with member states. All right, so as we move to the text, I want to mention that though we haven't looked at Articles 1 and 2 in the sessions, we have indicated earlier that these will come from the Terms of Reference as was provided to— as we've had an aspect that has been provided to each of us. And so generally that's the way we worked on it. What we also did really was just to move it from, should I say, a word of suggestion in terms of the terms of reference or the convention should have these objectives to stating them as actual objectives, actual principles, and actual So it's basically the language that has changed, not the content or the substance of what we have. And so with that, I believe we can open the floor for any comments. We'll start with Article 1 and with the general comments on Article 1, if we have any. So the floor is open. Thank you. open, please. So recognize the distinguished delegate from Ireland, please. Thank you,

Mr. Coolead. I'll make this statement— I'll make this intervention on behalf of the 27 member states of the European Union. The member states of the European Union reiterate their commitment to effective and fair international tax cooperation and our engagement in the UN process in a pragmatic, inclusive, and forward-looking manner, with a view to developing an instrument capable of securing the broadest possible participation. Consequently, we have actively participated in the different work stream meetings and provided our input regularly over the past few months. Our objective remains to ensure that the future convention strengthens effective and fair international tax cooperation while enhancing legal certainty and the coherence, stability, and predictability of the international tax architecture. It should seek to complement the international tax architecture, architecture in particular where gaps are identified, but not replace it. It is essential that the convention builds on and remains complementary to existing international instruments, internationally agreed standards and should avoid overlap or conflict with work already underway in other international fora. In this regard, we recall the terms of reference adopted by the UN General Assembly Resolution 70— 79/235, in particular the need to take into account the work of other international fora and potential synergies. We reiterate our concern that this requirement is not yet sufficiently taken into account and reflected in the current work. Consistent with this objective, and with the nature of a framework convention, we have consistently advocated for a convention conceived as a high-level instrument setting out objectives, principles, commitments, and institutional arrangements. We therefore consider it critical that the convention remains aligned with the mandate set out in UN General Assembly Resolution 79/235. In particular, it should retain its high-level nature and provide sufficient legal certainty, now and going forward, regarding its relationship with EU and international law, bilateral tax treaties, and other relevant bilateral, regional, or multilateral agreements, and with applicable domestic legal frameworks and constitutional requirements. It should be made clear that the Convention will not affect the rights and obligations of parties under other bilateral, regional, or multilateral arrangements unless the parties concerned expressly agree otherwise. Based on the adopted terms of reference, the text should also clarify that that the protocols are optional and binding only on those parties to the Convention that choose to become parties to the relevant protocol. We have consistently highlighted these issues throughout the negotiations, yet our remarks are still not sufficiently reflected in the drafting as the text has progressed. Clarification of these elements is essential to ensure legal certainty, predictability, and the broadest possible support for the Convention, and is a key condition for the active and constructive engagement of member states. Such clarifications are needed to foster confidence in the Convention and gain the support necessary for the Convention to achieve its stated objectives. Regarding the institutional framework, we recognize the role of the Conference of the Parties in supporting the effective functioning of the Convention. We stress the importance that the functions of the Conference of the Parties should remain facilitative in nature and should not result in the interpretation, creation, or modification of substantive obligations or without the express consent of the parties concerned. The current drafting does not yet provide sufficient safeguards in this respect. We also recognize the support provided by the Secretariat in this regard, whose functions should continue to remain limited to administrative and facilitative functions consistent with its supporting role under the Convention. We reiterate the importance of a consensus-based decision-making process within the Conference of the Parties concerning any matter affecting the substantive rights and obligations of parties. Consensus is necessary to ensure legitimacy, legal certainty, effective implementation, and the broadest possible participation. Departures from this principle could significantly undermine both the Convention itself and the willingness of States to participate fully in it. Any such decisions concerning the substantive rights and obligations of parties must be within the powers conferred on the Conference of the Parties by the Convention and without prejudice to the applicable constitutional and domestic legal requirements of each party. We recognize the extensive work that has been carried out in the 3 work streams since the last plenary, and we thank the Chair, the co-leads, and the Secretariat for their efforts. We strongly believe that further efforts are necessary to ensure an inclusive, transparent, predictable, and efficient negotiating process that takes into account the interests of all delegations and allows them to participate effectively and on an equal footing. Facilitating the negotiations in this manner will be key to preserving the integrity of the process and is essential for the Convention to achieve its stated objectives. Thank you, Mr. Colleague. Thank you,

Ireland, for that statement on behalf of your colleagues. As we mentioned earlier, you've raised some concerns, so as we go along, I'm sure we'll get some wording to address the concerns so that we can all look at it and see how best we want to consider them. Thank you. Thank you. Any other comment? Okay. United Kingdom, please. Thank you,

Mr. Co-Lead. Um, and, uh, I suspect that some of the comments I will, I will now make, um, will, uh, capture some of the spirit of what our colleagues from the EU27 just said, but obviously in regard to this article. And let me say, as this is the first intervention for the UK, um, thank you to yourself and to the Secretariat for all of the work leading up to this meeting. Um, and, uh, we're happy to be here. So, turning to Article 1. So, the UK welcomes the inclusion of the objectives in this draft. We think that the preambular provisions are, of course, important in providing clarity on the aims and objectives of the instrument. And we also recognize that, as you said, that these have been taken from the terms of reference. We did want to suggest the inclusion of one further objective, and I think this is very much in line with what our colleagues from the EU27 just said. To recognize the importance of strengthening cooperation and coordination with existing bilateral and multilateral arrangements, reflecting in particular Article 13.4. We think this would make clear that the Framework Convention is intended to augment existing cooperation where it delivers the Framework Convention's aims and provide greater certainty for state parties on how the Framework Convention is intended to interact with existing agreements and initiatives, thereby supporting the state objectives of certainty Okay, distinguished

delegate from Norway, please. Thank you, Mr. Kolid, and

thank you, Mr. Chair. We are happy to be reconvened here for the 5th session. It's good to see everybody. We will make some comments combined on Article 1 and Article 2. We recognize the role that Articles 1 and 2 are intended to play in setting out the overall vision and guiding framework for the Convention. These elements play a role in shaping the common understanding of the purpose and direction of our work, but at the same time, we believe there is merit to consider whether such provisions are best reflected in the preamble, where they serve as an overarching interpretive guidance while maintaining a clear distinction between the aspirational objectives and the specific obligations in the Framework Convention. Several of the concepts contained in Articles 1 and 2 are inherently broad and open to different interpretations. Terms such as fair and equitable are important for guiding our efforts, but it may be difficult to determine as a matter of legal interpretation whether a State Party has complied with them in any particular circumstance. So, in summary, our proposal is about placing the objectives and principles in the part of the convention where they can have the greatest practical and legal value. In addition, we continue to believe that there would be clear merit to reflect broadly recognized economic principles relevant to international taxation and the importance of economic and legal analysis in this text. Efficiency, administrability, and predictability, and minimizing unintended economic distortions are important considerations that contribute to sustainable tax systems and domestic resource mobilization and should, in our view, be recognized in the text. Lastly, in our view, we should consider including the important language in the TOR recognizing the consideration of the work of other relevant fora, potential synergies and existing tools, strengths, expertise, and complementarities available in the multiple institutions involved in tax cooperation at the international, regional, and local levels. Thank you. Thank you, Norway. Russian

Federation, please. Dear colleagues, good morning.

I'm very pleased to see you all again. We thank the Secretariat for this very complex and effective work, thanks to which we've gathered here today to discuss the text of the entire Convention in its substance. Overall, we would like to support Article 1 and Article 2 of the proposed draft. Why? Because we have carried out this work not only during the intersessional period, but also when we formulated the terms of reference and Essentially, the provisions of that document are reflected in these articles. So overall, we do support the text of these articles. Next, it is indeed worth noting the statements by our colleagues, including those from the EU, where they expressed their concerns. About ensuring that there is no duplication in the Convention and that the Convention is not something that would replace existing agreements. I think all of these questions would be useful to discuss a little later on when we are discussing Articles 19, 20, and 21 in substance. So all of those concerns that have just been expressed I think would be more effectively addressed during subsequent discussions. Thank you very much. Thank you, Russia. Colombia, please.

Microphone for the speaker, please. Good morning. Thank you to the Secretariat

for their work. Colombia would like to share a concern that has also been expressed from our colleagues from the United Kingdom, Ireland on behalf of the European Union, Norway, and the Russian Federation. We believe that it is very relevant to ensure legal security, legal certainty in the concepts that we're discussing. The principle of sovereignty is essential for international relations pursuant to the UN Charter, and it needs to be reflected in a preamble. As other delegations have said, a preamble could serve as a general criterion for interpretation, and we believe that in the first paragraph of that preamble, there should be a specific reference to sovereignty. Likewise, in the 2nd article, sovereignty appears to be secondary, comes in 2nd place. And finally, we believe that the outcome of this tool, of this instrument, should not be to generate additional obligations that already, in addition to those that exist in other treaties, they simply must ensure the implementation of those instruments. And to conclude, we believe that there should be a serious study of, uh, and serious consideration of an express reference to the principle Of no taxation without democratic representation. Thank you very much, colleagues and secretariat. Mexico, please. Thank you very much. Muchas gracias,

señor presidente.

Thank you very much, Chair. Welcome everyone back to New York. It is a pleasure to be part of this process. And thanks again to the chairs and colleagues for working on this text, which has grown and have expanded the— also the prospects for potential topics to be included in the Convention. Like colleagues, my country also believes that Article 1 and Article 2 should be contained in a preamble that would help to contextualize the technical purposes of the Convention as such and help us establish principles, guiding principles and objectives that can help us to develop and implement the early protocols. Likewise, we believe that from the very out— said when we negotiated the resolution in 2022 and the terms of reference, my country has been very clear, like other colleagues, on the fact that this convention needs to avoid duplications, that it needs to account for the work that has already been carried out in other fora, and should not create a process where countries need to revisit and reevaluate previously established treaties. Likewise, paragraph B of Article 1 talks about establishing a system of governance for international tax cooperation. If we are to retain this paragraph, it is essential to have a provision that links this to the fact that the convention must account for work that has been done in other fora and its outcome. Because we cannot have a governance system that does not take into account the work that has already been carried out and continues to be carried out by a number of countries in line with their various commitments. I also wish to say the following. Paragraph C.6.2, establish an inclusive, fair, transparent, efficient international tax system, and the negotiation process that we are going to have over the next 2 weeks must also follow these same principles. We must have a process where negotiations transmit the priorities of the various countries to the Bureau, and then the criteria to take up the various priorities must take into account technical merit and contributions to improving the final product and its protocols. Thank you. Okay, India, please. Thank you, co-lead. And I would like to—

before I begin my comments,

I would like to thank the Secretariat and the co-leads for the draft that they have produced. It's a result of a lot of hard work that has been put in by everyone, including all member states, and we've been witness to that in the work streams, and I think that is why we are here. as to the correctness of Article 1 and its language. India generally is in agreement that this article is drafted appropriately. There have been some concerns being mentioned around the room so far. One was the relationship of this Framework Convention with other work that has been done so far, with other commitments that member states have made either bilaterally or multilaterally. Now, that is indeed something that the Framework Convention and I would say the protocols that we finally negotiate that we'll have to deal with, but I don't think that the objectives or even for that matter the principles is the place to do this. The objectives and principles, they do something very different. In fact, I would even go so far as to say that put together they are not even the preamble. If we have to draft a preamble, we cannot replace the objectives and principles with a preamble. The preamble will have to be— will have to do something separately. Now, what is it that these objectives and principles articles do? They form interpretative anchors. For the articles that follow, for the principles and for the way we will draft the other articles of this Framework Convention. And matters like the relationship of the Framework Convention with other bilateral commitments, other multilateral commitments, they are important, but the objectives and principles is not the place where that needs to be fleshed out. There are separate articles for that which follow in the Framework Convention. So it cannot be an objective of the Framework Convention that it will— I mean, it will not— that objective article cannot lay down what it will do in relation to other work of the other work that has been done so far. That's a methodology. So I think we have to— I mean, look at each article separately as to what is its specific task, and I think the work— what the objectives article does has been clearly mentioned. I mean, the language of the objectives article serves that purpose. So I don't think that we need to build in any other goal within the objectives article. That has to be dealt with in an article somewhere else in the Framework Convention. And also, I also don't think that the objectives and principles articles can be done away with and we have a preamble which will then take care of that. So I think we are supportive of the language that is there in Article 1. Maybe when we get to Article 2, we'll make more specific comments on that. Thank you. Right, thank you. In the end, maybe if I'll intervene over here, at least

from the various conventions that I've looked at, generally there's a preamble, the objectives, and their principles as separate items. So I'm not too sure and clear about This issue of putting the objectives and principles as part of the preamble doesn't mean that we won't have any objectives for the framework and won't have any principles governing the framework, because the preamble is just an introduction. The substantive— that is what translates into this. So I think maybe as we are making these comments, let's take note of that. The other thing is that we have an article that looks at relationship between Um, between the agreements, other agreements and other things. So I'm not too sure whether we are saying we should do away with that article and bring it into the objectives, or we'll— but as we had during the intersessional session, I assume that we agreed that we should have such an article. Yes. And if that's what we said earlier, Then I believe that that discussion comes on. I'll be grateful if we concentrate on the objectives now. That's what we are talking about. If we have any addition we want or anything we want to take out, let's be specific on that so that we can look at each of the items as we go on. Agreed. We may have concerns, but now, uh, for repeating myself, we believe that now we have a document that we need to say add this, subtract this, or do that as we are getting down so that we get focused on this thing. So please, let's be minded of this and what we want to do. Thank you. Japan, please. Thank you, Chair. Thank you, colleagues and Secretariat, for preparing

the draft. Japan would like to align— Japan is aligned with the EU, UK, and Norway. I believe it's our common understanding that the objective of this Framework Convention is to promote and strengthen international tax cooperation. We understand that the current draft follows the wording of terms of reference, but to ensure effective international tax cooperation, it is necessary to take existing international frameworks and systems into account. Therefore, we agree with the United Kingdom's suggestion of adding an objective referring to such an important perspective, or maybe, for example, in the first line stating, while ensuring consistency with existing national frameworks and systems. Thank you. Thank you, Japan. Zambia, please. Thank you, Chair, and good morning. Since

this is my first intervention,

let me take this opportunity to pass my greetings to fellow delegates, civil society, and academia that are all here. And also let me congratulate you, Chair, co-lead, and the Secretariat for the work that you've done so far. Seeing that now we have more of, say, zero drafts in terms of the July 21st document that is before us. This shows some progress, but there's still a lot of work to be done and time is not really with us, and I think it would be important that as we meet this week, we make substantive progress so that as we meet for the 6th session, we should be tying up most of the issues. Allow me now to speak on behalf of the Africa Group. As the Africa Group, we fully support the text as is provided in Article 1. We also concur with the remarks made by the delegate from India and also to some extent from Russia. It is our view that The text reflects the objectives as provided in the Terms of Reference for the Framework Convention, and therefore it is our view that we should have the objectives limited to the objectives that are in the Terms of Reference so that we don't lose sight of what those Terms of Reference set out for the Convention to achieve. And these objectives were substantially negotiated and discussed when developing the terms of reference for the development of the Framework Convention, and therefore it's our view that this serves the purpose that we had agreed for it to achieve. We've also heard of the concerns from other member states of the issue of complementarity. We don't think this is the article that needs to deal with the— how the Framework Convention relates with other instruments and treaties. The Framework Convention, as provided by you, the co-lead, has a specific Article 21, and therefore we find it premature to start discussing that item which has got its own article which has been provided in the Framework Convention. And as India said, we also have the view that that particular aspect of how the Framework Convention relates to other instruments, whilst it's a very important issue, it's not fit and it's not fit for purpose to be under the objectives. On the issue of the preamble, we are of the view that the objectives be as is and they shouldn't be moved to the preamble. The preamble can be there, but probably further to the discussions, the preamble can mirror the preamble probably that's in the terms of reference, because in that preamble we are guided in terms of how the Framework Convention should sit and what it should reflect, the number of resolutions that have been put forth in there. And therefore it's our view that if we have to come up with a preamble, The preamble should not include the objectives of the prince or the principles as set out in this draft. Thank you. Thank you, Zambia. Malaysia, please. Thank you, Chair. As it's my first time

taking the floor, allow me to thank

the Chair, colleagues, Secretariat, and all members for their cooperation. And apologies for my voice. Malaysia welcomes the effort and input presented by the Secretariat in facilitating the discussions on Workstream 1 and appreciates the opportunity to provide comments on the draft framework convention dated 21 July 2026. Malaysia acknowledges the convention's objective on inclusiveness, fair allocation of taxing rights, capacity building, and combating tax avoidance. Malaysia would like to stress that in drafting the convention, the provisions proposed should be in line and consistent with the objectives under Article 1 and the guiding principles set out in Article 2. Malaysia wishes to highlight the need for explanatory documentation, for example, footnotes for each article, in order to avoid misinterpretation and to ensure the uniformity approach. For instance, for Further explanation should be provided regarding the concept of fairness as mentioned in Article 1 of the zero draft. The zero draft has outlined the relationship with other agreements under Article 21. However, while member states may wish to adhere to and align existing agreements with the convention, the draft should honor every member state's sovereign right to determine its tax policies and practices. While also respecting the sovereignty of other member states in such matters, as mentioned under Article 2B on principles. Malaysia notes that Article 5 envisages further work by state parties to explore and develop cooperative approaches to the fair allocation of taxing rights. Hence, Malaysia looks forward to further elaboration on this provision. Malaysia would like to seek for confirmation on the limits of flexibility of member states to explore different areas mentioned, for instance, under Article 5, Article 6, and Article 8. Niger would also further appreciate clarification on how the proposed articles in the convention, for instance, Article 8, would complement existing international tax standards and mechanisms, including those developed under the FHTP and the BEPS project. If the intention is to establish new or parallel frameworks, greater clarity is needed regarding their necessity, the gaps they are intended to address, and how, and how they will interact with existing standards and mechanisms. This will help ensure complementarity, minimize duplication of efforts, and avoid conflicting obligations for member states. Malaysia would also like to propose that the medium of assistance under Article 10 should not be too prescriptive since Article 25 does not permit reservations to be made to the Convention. Furthermore, some methods may not be able to be implemented due to domestic legal framework. Furthermore, for us, Article 11 provides a very wide scope for exchange exchange of information since it covers tax of every kind without room for reservation. Even under existing international instruments, the information exchange is still limited to information related to taxes covered by the relevant agreement. This article should take into consideration the current multilateral, bilateral, or other type of instruments currently in force. Chair, if you would allow me, I would go on to the other As well, we would like to comment on the commitments required under Article 12, Capacity Building. We require clear and definite information regarding each member state's obligation under this convention. Each member states have already made various commitments under existing international agreements, and greater clarity is needed to avoid potential conflicts. Article 13, related to the Conference of the State of Parties, should consist of balanced and neutral representation. For member states, while Article 15 refers to internationally accepted professional standards, but it's unclear which standards are being referred to. Malaysia is also of the view that paragraphs 1 and 4 under Article 20 on relations with protocols are not fully aligned because paragraph 1 is particularly not achievable if a state party is not bound by the protocols. This convention has to be implemented in its in its entirety since there is no room for reservation under the proposed article. If a state party is not bound by protocol, as mentioned in paragraph 4, it may suggest that such parties has the flexibility to depart from the convention in its implementation and elaboration. And lastly, the draft does not provide room for reservations under Article 25 in respect of any of the proposed articles, which may diminish flexibility for member states, and could potentially discourage wider voluntary participation and accession. I thank you, and thank you for giving me the time. Thank you. All right, thank you, Malaysia. And I think if we mentioned, as we

mentioned earlier, let's stick to the particular articles we are addressing as we go along so that there'll be time for all the other articles when we get to them. As you mentioned, we have some limitation in terms of time. And what I also realized that I realized that people members are combining one and two. So maybe we'll just combine those who who speak subsequently can combine the two of them just for ease of work. So. Thank you. Belgium, please. Thank you, Mr. Coley. Thank you, Chair, and thanks to the Secretariat for all

the hard work done on this draft of the Framework Convention. In addition to Ireland's statement on behalf of the EU member states, Belgium would like to return to the important and interesting point raised by the distinguished delegate of Colombia concerning the importance of national sovereignty and its possible inclusion in the preamble. We find the reference to sovereignty already in Article 2, but for us this doesn't seem to emphasize adequately the importance of sovereignty in tax matters. Belgium would want to go further and notes that other UN conventions often contain a separate provision on this matter. For example, Article 4 of the United Nations Convention Against Corruption is titled Protection of Sovereignty, which expressly safeguards sovereign equality, territorial integrity, and non-intervention by other states in domestic affairs. Given the particular importance of sovereignty in tax matters, we would very much support the inclusion of a separate article on the protection of sovereignty in Part 1. Thank you. Thank you very much. Indonesia, please. Thank you. Thank you, co-lead. Indonesia

aligns itself with the objective of establishing

a truly inclusive, a fair and transparent, and effective international tax cooperation framework that reflects the interests of all member states. We appreciate the effort of the co-lead in advancing the draft text. For Indonesia, this Framework Convention should provide a balanced foundation that strengthens international cooperation while recognizing each state's sovereign right to determine its own tax policy and domestic legal system. In this regard, Indonesia wishes to highlight 3 points. First, we attach particular importance to the principle of fair allocation of taxing rights. International tax rules should better reflect today's economic realities, including where markets are located, where revenues are generated, and where value is created. This is especially relevant in the digital economy, where economic participation often occur without physical presence. The convention should therefore provide a framework that enables more equitable allocation of taxing rights while supporting domestic resource mobilization, particularly for developing countries. As second co-lead, Indonesia believes that capacity building and technical assistance are indispensable for the effective implementation of the convention. We also see value in establishing an institutional mechanism under the convention to coordinate this effort and to avoid unnecessary duplication with existing initiatives. Third, while Indonesia supports enhanced international cooperation to combat tax avoidance, tax evasion, and tax-related illicit financial flows, we consider it equally important that the convention maintain legal certainty, protect taxpayer confidentiality, respect domestic legal framework, and complement rather than duplicate existing international instruments. Effective cooperation should strengthen implementation while preserving policy space for states. Co-lead Indonesia remains committed to engaging constructively We look forward to working constructively with all delegations to develop a framework convention that is practical, balanced, and future-oriented, one that enhances international cooperation while supporting sustainable development and strengthening the ability of all countries, especially developing countries, to mobilize domestic resources. We look forward to working closely with all delegations. Thank you. Thank you, Indonesia. France, please. Merci, Monsieur. Thank you, Chairman. Good morning, colleagues.

Since this is the first time that we're

taking the floor today, we'd like to thank you for conveying to us a comprehensive text that demonstrates the importance of the work achieved, but that should highlight the fact that a lot remains to be done both in terms of substance as well as the methods of work which has room for improvement including in terms of transparency and inclusivity. We also, without needing to repeat it, would like to express our support for the Irish statement on behalf of the member states of the European Union. As far as Article 1, we want to support the proposal of the United Kingdom. An international tax cooperation framework exists already, which is based on the work of other forums as well as bilateral treaties and multiple forms of cooperation. The objectives of the Framework Convention that brings us together today should be to improve this existing framework, to strengthen it, but not to replace it. So it seems to us that it's important to clarify that the objectives of this framework convention without harming the elements of the— the other elements of the convention. It's important to clarify this element of strengthening existing frameworks and ensuring coordination with existing frameworks to strengthen those frameworks. Thank you. Thank you, France. Israel, please. Can you hear me? Okay, thank you. We thank the Chair and the Secretariat

for providing the full text of the

treaty. For the first time, we can see all the conventions as a whole. We align with the UK Ireland, and the EU, and the others that talked before us. The preamble clauses of the convention should reflect the purpose of the convention. It should include provisions agreed upon by all states, and also it is essential to— that state sovereignty is reflected in those. I think that it's not as it should be. The treaty should aim to establish sound and balanced taxation while avoiding distortions. We don't want distortions of taxes. The taxes should be taxes, but and not for— not made for other things. We don't want to use them as a tool for other things. We have to make sure also to avoid duplication with other agreements and the work that is done in other places. Thank you. Thank you, Israel. Kenya, please. Microphone to Kenya, please. Thank you, Chair. Thank you, Chair, co-lead, and the

Secretariat for presenting the current draft. We support

the statement made by the delegate from Zambia on behalf of the Africa Group regarding Articles 1 and 2. We also support their inclusion as currently drafted, as we note that they reflect the text that has been proposed and that was guided by the terms of reference to be adopted in the Framework Convention itself. We also support the adoption of the objectives and the principles as separate articles, as opposed to placing them in the preamble, as has been previously proposed. As you've stated, Co-Lead, we see this reflected in other framework conventions like the UNFCCC and the Framework Convention on Tobacco Control. So, we do support their inclusion as 2 separate articles. Regarding the inclusion of the Terms of Reference text under paragraph 22 on existing tools and strengths, the Terms of Reference has made it very clear that this is an approach to be used by this Committee when it comes to developing the Framework Convention, and it is not an objective of the Framework Convention itself. It also makes it clear that the committee is to take what is existing into consideration, not to reflect them or complement them or adopt them, only to consider them. On the previous comments that the Framework Convention should not replace what is existing, the objectives are already very clear and they all use the word establish. This means that what is being developed here does not exist. And we do support that point because we have been saying that the existing frameworks have not been inclusive and they have not been fair, especially when it comes to developing countries. So we do not support the proposal to include an additional objective talking about reflecting or adopting the existing mechanisms. We have already been guided that this is simply an approach that this committee should use. Thank you, Chair. Thank you, Kenya. Papua New Guinea, please. Thank you, co-lead, for the opportunity to take the floor. PNG thanks

the efforts of the co-lead in progressing

the zero draft since our February meeting. We also acknowledge the Secretariat for their coordinated efforts to since the 4th INC meeting. We support the current text of Article 1. We lean towards having a separate preamble of the convention and are open to discussions regarding such a text. With regard to the relationship of this convention with other agreements, we note there is a specific article for this in the text and agree with India, Russia, and the Africa Group that the objective should not include a reference to this. With regard to paragraph A of Article 1, we suggest inserting the word system after the words international tax cooperation. Our reasoning is that paragraphs B and C refer to systems. B refers to a system of governance and C refers to tax system, a tax system for sustainable development. The Convention is intended to create a balanced, fair, transparent, and effective tax system first and foremost. Hence, paragraph A must include the word— should include the word system to relay this objective at the outset. Thank you, co-lead. Thank you, PNG. Austria, please. Thank you. We would like to express our appreciation to the Chair and the Co-Lead

and the Secretariat, first of

all, for the work done since the last plenary. Throughout the intersessional process, we have sought to reflect and reiterate well-established positions and key concerns in the draft texts. However, these efforts have to a considerable extent not been adequately reflected in the draft text. Thank you. Reflected in our opinion. We therefore encourage States Parties to revisit the original objectives of the underlying resolutions and to ensure that the Framework Convention remains focused on its intended purpose with a view to achieving a balanced and meaningful outcome capable of securing the broadest possible participation. Thus, we see also the need to underscore the necessity to maximize synergies with existing internationally agreed standards to avoid duplication in the interest of resource efficiency and coherence. Furthermore, in the light of transparency, we would appreciate a more balanced reflection of comments in the draft documents circulated for discussions in the negotiations. Concerning Article 2 specifically, we are of the opinion that the Framework Convention needs to mention that efficient international tax cooperation needs to recognize and take into account and be based on the principle that duplication of existing rules and standards should duly be avoided. This approach to efficient international tax cooperation has already been included in OP6 subparagraph of Resolution 87/230, and its inclusion in the principles of the Framework Convention should therefore be undisputed in our opinion. Where member states have well-established rules on improving rules in place, the focus of international tax cooperation at the United Nations in this forum should be on improving those rules and identifying issues with these existing rules rather than establishing a parallel set of rules leading to legal uncertainty and costly duplication, which cannot be in our favor. This is essential to maintain stability and to promote efficiency and effectiveness of the further international tax cooperation. Thank you. Thank you. Austria— Czechia, please. Thank you, Mr. Coty, for giving me the floor, and thank you, Chair. Thank you, Chair

and the Secretariat, for the work on

the draft. Czechia understands that the objectives and principles have drafted, similarly to what the ad hoc committee decided to insert into the Terms of Reference. However, we would like to give some comments and suggest amendments to the text reflecting our considerations of how the Framework Convention might function and the draft text in front of us. Regarding Part 1, in general, and in general regarding the sovereignty in tax matters, we would like to align ourselves with the suggestion of the distinguished colleague of Belgium regarding the separate article on tax sovereignty in Part 1. Now moving to Article 2, in particular Letter B, we would suggest adding wording that the Framework Convention respects States Parties' duties under international, supranational, and constitutional law, because we think that this is an inherent part of the state sovereignty that the Framework Convention respects. This wording could also be part of the separate article in Part 1 as proposed by Belgium. In this manner, we are also supportive of the suggestion of the distinguished Advocate of Austria to add a no duplication principle in Article 2 to ensure maximum participation. As regards letter D, we would appreciate information from countries that wish that this principle is in the text of the Framework Convention, whether they could explain to us how this general principle could guide the Framework Convention. In relation to letter E, We would like to add the word efficient after the words to ensure because we believe that the results should not only be equitable and effective but also economically efficient. In letter E, we would also like to suggest deleting the word landscapes because it seems to be redundant to us. In relation to letter F, this principle decreases legal certainty because it is not clear how it should influence other provisions of the Framework Convention, And as the distinguished delegate of Norway mentioned, generally the risk of different interpretation, it seems to us that in particular the question of fairness in allocation of taxing rights is the one that would— that allows for divergent interpretation, and we should deal with this issue elsewhere to avoid decreasing legal certainty. This applies especially if the principles are supposed to function as interpretative anchor as mentioned by the distinguished delegate of India. We would also, given the current discussion, we would also like to ask the co-lead whether and when the INC might discuss the preamble of the Framework Convention. Last, we have a general minor point regarding the drafting of the Framework Convention, because the text currently contains wording such as States Parties, State Parties, Parties, and Member States, and we think that this language should be aligned. Thank you very much for considering our suggestions. Thank you. suggestions. Okay, thank you, Cecilia. Côte d'Ivoire, please. Go ahead. Thank you, Chair. Good morning, everybody.

I will be speaking French. Côte d'Ivoire. I'd like to thank the Secretariat for

all the work it has done, allowing us to have a comprehensive text which will be considered, examined throughout the session. My delegation would like to also express wholehearted support for the position of the African group, which was also supported by Kenya in particular, and to some extent by Russia and by Zambia. Côte d'Ivoire would also like to express its support for the draft of Article 1 as presented to us. This article very clearly sets out the objectives of this Convention, which were established by the Terms of Reference. In fact, the Terms of Reference are our roadmap, our guide, so that there's a clear risk of introducing among the objectives of the Convention objectives that were not envisioned in the Terms of Reference. There's a whole range of objectives that we could have included, but our work is part of— is established by a framework which was determined by the Terms of Reference, and it would not be appropriate to stray from that. As for the proposal of inclusion of other objectives, namely sovereignty of states and the links to all the existing tax frameworks. I believe that the various articles of the convention are already focusing on these issues so that we don't think it would be a good idea to address this matter in the first article that deals with the objectives. Likewise, we think that the preamble is not really the place to speak of principles and objectives. Preamble— the preamble's goal is to establish the context, and similar to other framework conventions that have already been adopted and developed— developed and adopted by the United Nations, we think that in addition to the preamble, preambular, we need an article that focuses on objectives and another article on the principles. Côte d'Ivoire would like to, in conclusion, express once again its support for the process of negotiation of the Framework Convention and its additional protocol, as well as our commitment to work with all delegations and the Secretariat to achieve the goals of this committee. Thank you very much. Merci. Thank you, Côte d'Ivoire. Senegal, please. Merci. Thank you. Thank you, Mr. Co-chair. Good morning, ladies and gentlemen.

Congratulations to the Secretariat for the

work that is already done by presenting to us a text that will kick off our discussion on the substance. And as we discuss the substance, I think it's very important for us to have a very pragmatic approach so as not to fall into the trap of certain types of discussions I'll start by expressing our support for the African Group for the comments made, which explains our support for the objectives and principles. These objectives and principles flow from the terms of reference, which today are the very reason for our our presence in this room. And as mentioned, nothing was changed in these principles and objectives. I think from the terms of reference, so it's a good starting point, as long as we all agree that it's important to have terms of reference and the terms of reference were adopted. So I think we can streamline our use of time not to focus too much on this. Now, as far as the preamble, it's already kind of touched upon in the various provisions. It was already mentioned that the preamble is already based on certain previous texts. For example, transparency is already mentioned in the objectives. We have certain resolutions that to speak of strengthening cooperation, tax cooperation, which also was mentioned in the objectives and in the principles. We also have resolution that mentions mobilization of resources. So, and you can also find in the last sentence of the objectives, all these elements are already reflected here. So maybe the preamble, in fact, having a preamble would be redundant. As far as the interaction with other instruments, I believe that it's also very important to follow the logic of the Convention because interaction with others have already been defined in one of the articles, Article 21, and this could be better highlighted when we actually get into the technical discussions, that is when we can discuss the interaction with other conventions. As far as aspects related to synergies and complementarity with existing tools, again, we need a practical approach. When we get into the substance, for example, Article 22 of the Terms of Reference mentions this, it's in the course of the work, but now initially we're establishing a framework for the Convention. When we get into the practical aspects, for example, on lessons learned and scope, these are technical aspects, and then we'll discuss how we can make this text more useful. The same thing applies to the issues of sovereignty. All the principles and objectives that we have seek to make it possible to strengthen tax cooperation and also allow each jurisdiction to exercise its sovereignty if the principles mentioned in this convention, if in case they would not be respected in these negotiations or future ones. Thank you very much. Thank you. Okay, so we're gonna break for 5 minutes just to allow everyone to move his legs, and we're gonna come back in 5 minutes.

Yes, exactly. So, 5 minutes coffee break. Thank you. Okay, welcome, welcome back, everybody. Maybe we can quickly settle down. Okay, so now have the distinguished delegate from Luxembourg,

please. Almost finished for the morning. Before Landsberg comes in, sorry, the Chair will make a statement. Oh, sorry. So before we continue the discussion, I would like just to let everyone how I see it. Thank you. So it's— this is my perspective about the discussion

for Article 1 and Article 2, which is objectives and principles. We need to keep in mind that the objectives and the principles, they are leveraged, they are extracted exactly from the TOR, and the TOR has been adopted by resolution from the General Assembly meeting. And then that means that this resolution is giving the mandate the current committee what they should do, what is their objectives, and what's the guiding principles in doing these objectives. And deciding now to go and amend or do any changes in the objectives and principles may create a conflict with the General Assembly resolution mandating this committee with, with its homework that they should do. Then we have 2 conflicting documents that we are requiring the General Assembly Assembly to adopt. So maybe we need to consider in the discussion that principles and objectives, it's a little bit difficult to do any changes for them because this may create— take us in a different loop of what an instrument and what objectives should be guiding, given that we have already a General Assembly resolution already from this. And that's, that's the reason that we are just extracted the objectives and principles to be as, as the first part of this convention, uh, and the guiding form for it. So please consider that already we have an instrument stating this and giving this. And in the TOR, you have the objectives of— if you're gonna read the chapter of the, of the article of objectives, you have that the convention objectives should be. So this is the objective stated in the TOR adopted by General Assembly. So what if we're gonna change it right now? We can't go back and change the TOR, of course, and the TOR is mandating this committee to do this. So just to, to bring it under your eyes to consider while we are Moving on with the discussion, thank you. And in addition, that the reason why we opened it up was just to be sure that what is in the TOR is the way it's been reflected, not necessarily to add

to it. But then we have something. So what we have is that how it's been reflected in. What we have. So just to give us that direction as well. Luxembourg, please. Thank you, co-facilitator, for those clarifications, and thank you, Chair, for the explanation. We also thank the Secretariat and colleagues for

their efforts over the past few months. Luxembourg will be brief. We will support the observations already formulated by the chair and the reps of the EU, Belgium, and France, among others. We believe that the Framework Convention must remain a framework instrument with high-level provisions that will also allow for the respect of the national sovereignty of member states. It must also account for existing international norms and standards to avoid legal uncertainty as well as duplications and overlap that could create difficulties, for example, when it comes to the interpretation of bilateral tax agreements. And finally, we stress the importance of ensuring a transparent and inclusive process, and we believe that when positions differ, the negotiation text must present various options in an equitable and clear manner so that we can all have discussions on the same basis. Thank you. Thank you, Luxembourg. Nigeria, please. Thanks, Chair. And it's noon, so good afternoon, colleagues and colleagues. Thank you so much for the very wonderful

work that has been done to bring this one

to develop this draft which is for consideration by the committee. I think the African group has spoken and I also want to reiterate that my comment is also to further emphasize what Zambia presented on behalf of African group and supported by Kenya, Sierra Leone, and other including Senegal, who spoke ahead of me. Co-chair and colleagues, I think the term of reference is our guide for this assignment, and that we have INC is because we have a body that has set us up, and the terms of what we are supposed to do, what we are supposed to deliver, had been given unto us. Our understanding of a term of reference is that it defines the purpose, the scope, and responsibilities of a committee. So by that, the purpose, the scope, and responsibility of this INC, this negotiating committee, has been so defined by that terms of reference. And we will take a look at the objective and the purpose as we have it in Articles 1 and 2. It speaks succinctly and captures exactly as we have it on the Terms of Reference. For us, we see the Terms of Reference as the mandate, or if you like, as the constitution that has been given to us by which we are going to— we are expected to operate. Changing it, amending it in any form will mean that we are going ultra vires the mandate that has been given to us. So as Nigeria and of course as African group, we believe that Articles 1 and 2 are already in tandem with the terms of reference and And we want to encourage that we stand by it in view of the fact that there are a whole lot of articles that we still have to deliberate upon and time is usually of the essence. So, Mr. Kholit, for us, we see this as good enough, Articles 1 and 2, and on behalf of Nigeria and the entire African group, ISO SWAMI. Thank you. Thank you, Nigeria. Italy, please. Thank you, Chair, and to pursue on discussion on a more practical basis and refer to a legal text, we appreciate it a lot. We would

like to align ourselves with a statement

read by Ireland in the name of the 27 EU member states. And we also would like to reiterate our engagement in the UN process, which must be inclusive, transparent, and based on a cooperative approach aimed at establishment high-level principle framework. On the discussion of Article 1 and 2, we acknowledge that these articles are directly derived from the TOR, which unfortunately had been unapproved by consensus. We had a long discussion about the right places to put some principles, some approaches, and in the end we have this forum which guides us. But we believe that the success of the Framework Convention depends on the broad acceptance, which has to take into account the interests of all delegations and allows them to participate effectively on an equal footing. We heard widespread favor to maintain Articles 1 and 2 in the text of the Convention, and we saw in some precedent that this has been done in other framework conventions. But we have examples in treaty law where objectives and principles are indeed in the preamble. In any case, we would like to stress the importance to have a preamble which, according to the Vienna Convention on Treaty Law, provides a context for interpretation purposes, while the preamble of the TOR just makes a list of documents which govern the process but do not provide the context that we would ask for. In general, we believe that starting to establish the shared interpretation guidance at this stage by the INC would help to prevent divergent possible domestic interpretation in the future and reduce the risk of overlapping or conflicting taxing claims. We would like to align ourselves with the comment made by UKNO and others, and we ask for an explicit reference on the existing tool, strength expertise, and complementarities which are available in the multiple institutions involved in tax cooperation and international, regional, and local levels where they work well, following paragraph 22 of the TOR, which is indeed an approach, but it is very important for us. The Framework Convention will be not introduced in a vacuum, but will be complement, hopefully filling the gaps that the system of governance already is in place, and we would like to see an explicit reference of that. Thank you. Thank you, Italy. Brazil, please. Good morning, Colette, and good morning, colleagues. We have been through this discussion several times, Uh, there are elements mixed in most

of these articles. There are principles

mixed in the objectives. There are, there are procedural rules in the objectives and in the principles. So, but all in all, we, we are happy with the text. We support the text. Um, it could be adjusted. It could be We could have the objective of having just one paragraph. Paragraph A would be enough. Just paragraph B would be enough. Or maybe even just paragraph C would be enough to cover what we intend to do here. I think we are in this environment sharing a bounded rationality. We have a great understanding of the expectations and how we will Behave, how much you insist in positions that are already covered in other forums or the rules. We know that, we know our limits. I mean, how, how much you push in each direction in each time. And having that in mind, I don't see the need or even consistency to have a reference to other forums here. I don't think that it would fit well to begin with. It would put us in a subordinate or a second role in our job in the future. Complementarity, we will— I think the understanding behind what we are doing here is that we intend to revisit some rules, not just the gaps. But of course, we will proceed with due caution, with a precautionary approach to it. We will interact, we will discuss, we will grow legitimacy and consensus as much as possible in each proposal that we will develop in the future, in each protocol. Having that in mind, we support the wording as it is for the objectives. Could be different, but it's— it addresses the goals that we have in mind and how we perceive ourselves as developing our activities in the future. I don't see weaknesses that are so concerning or that could create so much uncertainty there. In relation to the second article, once again, it includes a lot of principles, of different nature governing cooperation itself, and in some cases governing what could be domestic policies. When we say about simple rules, that also it's a type of tax policy principle that it's mainly targeted domestic rules. We understand that the Article itself could have more principles mentioned, but we are happy with it. If we are reopening to mention more principles, we will be happy to include a few more, including progressivity and broad-based and so on. But again, for the time being and for the position, So far, we would support the wording as it stands. Thank you. Thank you, Brazil. Sweden, please. Thank you for giving me the floor, and thank you, co-lead and the Secretariat, for presenting the updated draft. In addition to the statement made by Ireland,

We do also want to echo previous

speakers such as Belgium that mentioned the importance of respecting sovereignty in tax matters. It's important that member states has the sovereign right to decide its own policies and practices. We do also want to express our appreciation for inclusion of subparagraph 2c on international human rights law. in this context, as well as subparagraph 2 on sustainable development, which in our view could be strengthened by adding also a reference to gender equality. Finally, we'd also support the question raised by Czech Republic on when any discussions on the preamble will take place. Thank you. Thank you. Iran Islamic Republic, please. Thank you, Mr. Khalid. Bismillahirrahmanirrahim. As many distinguished colleagues have rightly emphasized, for the Islamic Republic of Iran, the

principle of state sovereignty remains

a fundamental consideration in any international undertaking. Including the United Nations Framework Convention on International Tax Cooperation. This principle is indispensable and should be duly reflected in our consideration of the whole document, initiating from Articles 1 and 2. In this regard, we also wish to recall the important clarification made by the distinguished Chair of the Committee at the outset of today's meeting, namely that the The outcome of this session is not intended to constitute a clean or final text. Allow me to further underline that any eventual final text of the Convention will in any event remain subject to the necessary approval of the— and endorsement by the competent domestic authorities of each Member State in accordance with its respective constitutional and legal processes. We therefore believe that the discussion of Articles 1 and 2 should proceed with due regard for these fundamental considerations, ensuring full respect for the sovereign equality of states and preserving the authority of each state to complete its domestic procedures before assuming any international legal obligations. Thank you. Thank you. Estonia, please. Thank you. And our gratitude goes to everyone who has worked hard to bring this text on the table in time for the 5th session. At some point, I thought that I might lower

my flag, especially after

hearing that we can't change anything that was already in the terms of reference, that inevitably raises the question why we are even discussing this text. But since we are, and I totally agree with my Brazilian colleague here, we have— we seem to be getting stuck in this conversation, and it probably will not be the last time when we return to the objectives and principles. It might be, as my colleague from Italy mentioned, because the DOR was not a consensus document, and there are several countries that do deem that it is important to mention the work of the other forum in principles as well. Just From purely lawyer's perspective, I wouldn't do it under the principles. But if I look at the text that we already have in Article 2, and it does list several elements that we need to take into account, then it wouldn't really do any harm if we would mention the work, the existing work, in an international text among the principles as well. I have to sort of draw a parallel here with subparagraph D, which pretty much copies Article 4. I do recognize that we have this text in the TOR, but just to illustrate that from our perspective It wouldn't hurt to add the reference to the existing instruments and work in another forum here as well, because we do have an example in sustainable development in subparagraph D, which is then sort of replicated in Article 4. So there is a certain repetition. Also, I would like to support what my colleague from Belgium has said regarding the separate article on sovereignty, and we also find the questions presented by Czechia very relevant. Thank you. Thank you. Republic of Korea, please. Thank you, colleagues, for giving me the floor. Good morning, distinguished guests and colleagues. As this is Korea's first intervention at this plenary meeting,

we would like to begin by expressing

our sincere appreciation to the colleagues and the Secretariat for their dedicated efforts in preparing for this co-lead draft. As for Article 1 on objectives, We align with the views expressed by the EU, the UK, Norway, and France and others. We believe it would be beneficial to clarify that the framework convention should build upon and complement existing bilateral and multilateral frameworks for international tax cooperation rather than replace them. Such clarification would help ensure coherence with the existing international tax architecture, avoid unnecessary duplication of rules and mechanisms, and enhance legal certainty and the effective implementation of the convention. In this regard, we support including language recognizing the role of existing bilateral and multilateral frameworks in achieving the objectives of this convention. Lastly, we also echo Belgium and others who recognize the importance of respecting the tax sovereignty of states. We believe it is an important guiding principle for effective international tax cooperation. Thank you. Thank you. Philippines, please. First of all, thank you to the Chair and our colleagues at the Secretariat and the work stream leads for our work in the past months. The Philippines strongly supports

Article 1. Establishing an inclusive

UN-led tax governance framework ensures all nations have an equal voice in shaping global tax rules. Noting this, we are agreeable with the inclusion of paragraphs A, B, and C, as they are aligned with the TOR and they meet the requirements of defining why the framework convention is being entered into. Currently worded, the article covers items very much important to the Philippines, such as establishing an equitable and effective international tax system for sustainable development, strengthening domestic resource mobilization, and the fairness of international tax rules. Also, in Article 1, we support India Russia, the Africa Group, Zambia, Papua New Guinea, on the non-inclusion of provisions on complementarity, synergies, and on current frameworks. On Article 2, we fully endorse the principles outlined in the said article, most especially the principles on national tax sovereignty and universality, recognizing different needs and priorities and capacities of each country. The inclusion of certain principles of Simplicity, transparency, and flexibility of rules are essential to ensure efficient tax administration and ease the compliance burden on taxpayers and revenue authorities alike. We agree with the previous statements on fixing what the term they use to refer to parties of the Framework Convention, and this one is a continuing comment all throughout the text of the Framework Convention. Thank you very much. Thank you. Audrey Earle, please. Thank you, Chair. First of all, we want to thank the co-facilitators and the Secretariat for the draft We also applaud the efforts taken and the progress achieved so far. As far as

Article 1 and 2 of the Framework

Convention regarding the objectives and principles, we support the statement made by Zambia on behalf of the African Group, but also by other colleagues from other countries. Such as Senegal, Nigeria, India, Russia, and Côte d'Ivoire. On these issues, we think that we have discussed extensively principles and objectives of the convention in elaborating the terms of reference of the Framework Convention. And bearing this in mind, we support the text proposed. Because it faithfully reflects what we discussed at length and debated during the work on the Terms of Reference. As far as existing norms or rules and the interaction of this Convention with other instruments, I just recall that we're here because of some of the difficulties raised by countries. Difficulties and challenges raised by countries demonstrate that not everything is perfect with existing instruments and that we need to work in a transparent and inclusive way to remedy some of these problems. So the process that the Framework Convention must set up is a process that is supposed to become— that is supposed to complete and strengthen existing instruments and improve some of the existing imbalances. And so bearing this in mind, we support the text proposed for Article 102. Thank you. Thank you. United Republic of Tanzania, please. Thank you, colleague. Tanzania aligns itself with the statement delivered by Zambia on behalf of the Africa Group. We also associate ourselves

with the views expressed by India, Kenya, Papua

New Guinea, Côte d'Ivoire, Senegal, Nigeria, and Algeria in support of retaining the current structure and the substance of Articles 1 and 2. Colleagues, in our view, the current drafting of Articles 1 and 2 is fully aligned with paragraph 7 of the Terms of Reference, which clearly sets out the objective of this process at the establishment of the United Nations Framework Convention on International Tax Cooperation. The mandate given to this committee is not to merely supplement, mirror, or restate existing instruments, but to develop a framework convention that responds to the GAPS priorities and ambitions that led member states to establish this intergovernmental process. We therefore support retaining the existing draft of Articles 1 and 2. These provisions reflect issues that were substantially discussed during the terms of reference process, in which all delegations fully participated and which were ultimately adopted. At this stage, we should be careful not to reopen discussions that were already settled through that process, particularly where the present text faithfully reflects the agreed mandate. Tanzania also agrees with the point made by previous delegates that paragraph 22 of the Terms of Reference is placed under the section on approach and timeframe. In our understanding, colleagues, that placement was not a mistake. Paragraph 22 provides guidance and was not intended to require the convention to inherit the scope and limitations of existing frameworks. For these reasons, Chair, Tanzania supports the African Group position that the preamble, Articles 1 and 2, should be retained as currently drafted. I thank you. Thank you. Azerbaijan, please. Thank you very much, Mr. Kouloudis. Azerbaijan welcomes the UN Framework Convention on International Tax Cooperation. We consider this convention an important

opportunity to establish more

inclusive, fair, and effective international tax system that reflects the priorities and capacity of all countries, particularly developing countries. In this context, we would like to offer brief comments on Articles 1 and 2. Regarding Article 1, Azerbaijan supports the objective of establishing inclusive, fair, and effective international tax cooperation framework. We suggest emphasizing that the convention should enhance domestic resource mobilization while ensuring tax certainty, preventing both double taxation and non-taxation, and avoiding unnecessary administrative burdens. Regarding Article 2, Azerbaijan supports the principle of universality, tax sovereignty, and fair allocation of taxing rights. At the same time, convention should fully recognize the different capacity of developing countries and provide for practical, proportionate, and administrative rules. We also suggest that principles expressly refer to consensus-based cooperation, legal certainty, and the protection of confidential taxpayer information. Thank you very much. Thank you. Okay, Cecia, please. Thank you, Mr. Corbett, for giving me the floor again. Czechia just briefly wanted to react to the interpretation of the Terms of Reference in relation to the current discussion.

The Terms of Reference states

that the Framework Convention should follow certain objectives and principles enumerated there. In our opinion, the Terms of Reference are simply issuing a recommendation to the INC. Otherwise, the General Assembly would use the words shall or must, which would apply an obligation to use certain text, as we discussed a few years ago. Thank you. Czechia believes that in relation to Articles 1 and 2, the General Assembly appreciates the fact that the INC should use the text of the Terms of Reference as a starting point for the negotiations, but the INC is not obliged to stick to the wording used in the Terms of Reference if a justifiable need arises. Otherwise, we would also be asking the same question as the distinguished delegate from Estonia about the usefulness of the discussion of Articles 1 and 2 if the resolution would not allow the INC to change change the text. Thank you. Okay. All right, India, please. Thank you, Chair, and thank you for giving me the floor a second time. Since the last time we spoke, it was only in the context of Article 1, so we decided we can use that to take a second shot.

In fact, the Chair had pointed

out that there is a certain structure that has been decided in the terms of reference which includes objectives and principles. Now, that structure— respecting that structure is not a yoke that we are struggling under. There is an operational logic to that. Article 2. Now, this is a framework convention that deals with tax matters. Now, if we look at each of these sub-paragraphs from A to I, these are not preambular text. Each of these points can be linked to an actual deliverable in the context of a tax document. We are all tax people, tax professionals, or tax people who work in the tax department in this room, and if we look at each of these, we can connect it with an actual deliverable related to tax. Therefore, these points which are in Article 2, these are not a preambular text. A preambular text, on the other point— on the other hand, would only provide a context. It would provide the motivation. It would provide a shared understanding as to why parties would come together to do some work. Now, as the distinguished delegate from Italy had mentioned, that the preamble of the Framework Convention, what was there in the UN General Assembly resolution, it mentioned 4 documents. But apart from mentioning those 4, listing out those 4 documents, it said that the text of the Framework Convention should reflect inter alia the following General Assembly resolutions. That means that everything that was there within those resolutions must be reflected in the Framework Convention. Principles of sovereignty, principles of taking into consideration the work of other organizations, the work that has been done so far has been reflected in Resolution 78/230. So therefore, even for that matter, if there were no specific article in the Framework Convention, it's already taken into account that we will respect principles of sovereignty, we will respect taking— the concept of taking into account the work of other organizations. Therefore, there is— we don't see any necessity to replace Article 1 and Article 2 with a preamble. We can have a preamble, because that's something probably we will have at some point of time. But that does not mean that we need to disrupt this structure, because as I said, each of these items within these 2 articles and also Article 2, they reflect an actual tax-related deliverable. So therefore, having a preamble is one thing, but that does not necessarily mean that we should disrupt the structure that we have all agreed to for this Framework Convention. Thank you. All right, thank you. Ghana, please. Thank you, Co-Chair and colleagues. We would want to thank you for the opportunity to take up the floor, and as this is our first, I would want to congratulate you and also commend you

for the great work you've done with

the Secretariat concerning the drafts that we have today. Ghana aligns with the position of Africa Group as delivered by Zambia and echoed by Kenya, Côte d'Ivoire, Nigeria, and other African countries, as well as India, Russia, Brazil, and Philippines, in supporting the current text of Articles 1 and 2 as they are. These articles clearly outline the objectives and the principles as were established in the adopted Terms of Reference. Ghana is mindful of the overall intended outcome of this Framework Convention, which is to establish effective international tax cooperation to deal with the existing tax-related challenges, and that is not meant to complementary to any other existing instrument. As has been noted by the distinguished delegates from India and the co-lead, the relationship of this FC and other existing agreements is clearly set out in the various articles in the Convention. Therefore, we believe that the current text as presented in 1 and 2 articles are sufficient. We thank you. All right, thank you again. Germany, please. Thank you, Mr. Kohl. Let me say, first of all, I'm very delighted to see everyone again. Germany also appreciates the effort support and the hard work of the Secretariat and you,

Mr. Kohl, in preparing this session. It is really

encouraging to witness steady progress in our work. And having said that, let me jump into Articles 1 and 2. From Germany's perspective, the Framework Convention must remain a genuine framework instrument establishing common objectives and guiding principles rather than detailed legal obligations, the scope and implementation of which also remains uncertain. In light of this, the coexistence of Articles 1 and 2 on one side and Articles 4 through 11 on the other gives already rise to some concerns in itself. Some subject matters, as was already pointed out by Estonia, if I'm not mistaken as substantial sustainable development, for example, are found in principles and commitments and are hard to distinguish from each other. At the same time, the current draft continues to contain numerous binding obligations without sufficiently defining their legal content or the concrete actions expected from state parties. Such provisions do not provide the legal certainty required of an international convention and therefore are, in our view, not acceptable. We share the view that the convention should operate in a complementary manner and should not create uncertainty regarding existing legal obligations. Yet the relationship between the Framework Convention and existing international agreements, including bilateral tax treaties and established multilateral instruments, remains insufficiently clarified. Existing international standards and mechanisms should be expressly recognized and relied upon wherever they already achieve the objectives pursued by the Convention. Duplication of existing mechanisms should be avoided. We therefore echo the voices calling for additional objectives and principles to this effect. And in reaction to some of the previous speakers, the fact that the relationship with other agreements is already addressed in Article 21, that's in our view not precluded from being anchored in Articles 1 and 2, just as one would also not argue to delete the provision of Article 2, paragraph F, for example, simply because Article 5 already exists. And as the distinguished delegate from India said previously, Articles 1 and 2 are supposed to provide an overarching interpretative anchor. So, in contrast, Article 21 is a provision that is rather supposed to translate these objectives and principles into legal effects. I also agree with distinguished delegates from Czechia and Estonia. It is true that the Terms of Reference guide the INC to take into account the work of other fora and potential synergies as a means of an approach to our negotiations, but we are currently in the very midst of these deliberations and the terms of reference do not preempt the outcome of these deliberations. In particular, they also do not preclude us from identifying the necessity and merits of a provision that addresses complementarity and coherence either in as an objective within the framework convention or as a guiding principle for the work to be conducted on its basis. Thank you. Okay, thank you. Saudi Arabia, please. Thank you, co-lead, and thanks to the secretariats for their hard work on this draft. Saudi Arabia acknowledges the different views expressed. However, we support the articles to remain

as drafted. The current text reflects

extensive discussions during the negotiations of the terms of reference with carefully balanced compromises. We believe that those discussions, especially the discussions that extended beyond the tax experts' to other relevant subject matter experts should not be reopened or revisited for those matters. And in our view, the current draft provides an appropriate foundation for the Framework Convention. Thank you. Thank you. I think UNESCO Belgium has spoken. How many minutes do we have left? Okay. If you indulge me, Mexico and Belgium, and Burkina Faso hasn't spoken yet. If they can speak and then we'll take the 2 of you. So Burkina Faso, please. Then

we'll do Mexico and Belgium. Microphone to Burkina Faso, please. Thank you. Burkina Faso would like to congratulate the Secretariat for the work that was done that has made it possible to have this draft. Burkina Faso aligns itself with the statement made by Zambia on behalf of the African Group.

Supported by countries such as Côte d'Ivoire, Senegal, Algeria, Nigeria, India. Our delegation is in favor of maintaining Articles 1 and 2 as drafted because this is a provision that pertains to the articles, to the principles and objectives, and is in line with what was already agreed on in the Terms of Reference, and that was discussed previously. So for Burkina, these articles confirm an inclusive approach as far as adopting the Convention, and these provisions put raising mobilization of resources based on the principle of equality, also the allocation of resources should take into account the sovereignty of various states, which is important. Thank you. All right, thank you, Burkina Faso. Mexico, please. Thank you very much, Mr. Co-Leader. I'll switch to English for this intervention. Just want to thank colleagues around the room for, for their perspectives on what we should do with Articles

1 and 2. I think it would be remiss of me not to say that

we've had this conversation for the past 3 and a half years, from the resolution to the terms of reference to, to, to the part of discussing the convention and the protocols. And if I'm not mistaken, the approach that's been taken has been normally that the text that we adopt previously will remain unchanged, and then we go to the next part of the process and then we change it. I understand that in the terms of reference there were some provisions in the resolution in that did not make it to the Terms of Reference, particularly those on the focus on sustainable development and to combat IFFs. Then we came to the room and the argument was that sustainable development and IFFs were too broad a term to discuss protocols related to them. And then we've had the discussion on sustainable development. What does that mean and how do tax experts and frameworks take that into consideration? So the approach has been a little bit inconsistent in our opinion, but we respect the fact that because of the difficulty of providing objectives and principles for the Convention at this moment, the decision was made to go back to the agreed language from the Terms of Reference, which were very, very carefully negotiated. So in that sense, we also would like to agree with other colleagues that just because there's an article that relates to some of the principles and objectives, that should not preclude us from also reflecting some of these elements as principles. So as my colleague from Italy put forward. I think that for us, we are also going to submit adding OP22 of Article 4 of the Terms of Reference as a principle. We're talking about universality in approach. Why not talk about complementarity with the work of other fora? For us, we believe that this is an integral part of the negotiation and also of the outcome. For some of us, the decision to ratify the protocol or the convention will rely ultimately on the complementarity we see with the other tax treaties that are negotiated outside of the UN. And if that allows us to move forward, then all the better to have this safeguard, if you want to call it, as part of the principles. And then on the discussion on whether or not we should repeat some of the principles as articles, then, you know, the dimension of sustainable development being one of the articles outside of the principles We fought very hard to keep that in because it's the mandate of the resolution. But if the argument is that we should not be duplicating, then I would be remiss to say that at some point we also wanted an article on human rights. So I would not want us to go through that road in which we're saying that we cannot have duplication in principles and articles. We should just find the right synergy so that they both reflect each other. I would also highlight that H, also on taxpayers and government certainty, relates to allocation of fair taxing rights and other articles and provisions. So the principles are supposed to serve as a general kind of guide on what the articles in the convention should refer to. So in this regard, we would ask other colleagues to also at least indulge the conversation of, if not modifying Article 1 and 2 and not going back to the preamble discussion, to at least reinforce Article 21 by bringing in OP22 of Article 4 in the Terms of Reference. Thank you. All right, thank you. Belgium, you have about a minute. We're actually at 1 o'clock, so we'll lose interpretation in a few seconds, so please be snappy. Okay, thank you. I can say it briefly. We want to align with what the distinguished delegate of Mexico

Italy, Estonia, and Czechia sat before us, and we believe we are here to negotiate still, so we can still make changes and proposals, like the proposal

to add, to put the principle of national sovereignty in a separate article, as has been done in the UN Convention Against Corruption, in the UN Convention Against Transnational Organized Crime. I think a cornerstone of international tax cooperation is national sovereignty and the protection of our national sovereignty on the tax matters. Thank you. Thank you, Belgium. Now, for the intergovernmental groups and stakeholders, we'll take you immediately after lunch, then we'll move on to the other articles. So with that, I want to hand over to the chair. Thank you all. And thanks for the discussion. We're

gonna convene in the same room this afternoon at 3 o'clock. Have a good lunch break. See you. Bye. Thank you.