(6th meeting) - Fifth Session of the Intergovernmental Negotiating Committee on the UN Framework Convention on International Tax Cooperation (INC Tax) - 3 to 13 August 2026 General Assembly Date: 5 August 2026 Language: English Transcript: https://transcripts.un.org/en/asset/k1f/k1ffrc9ce0 Transcripts available through this tool are created by using automatic speech recognition and are not official records nor official documents of the United Nations. Official records and official documents are available on the Official Document System of the United Nations. --- Co-Lead · Khalid [18:01]: Can we settle down please? We are all welcome back from lunch. I hope we had a good lunch. Those who needed to stretch, I hope you were able to stretch. We want to move straight into business and we are currently looking at the Looking at Article 10 on mutual administrative assistance, again, we've been able to put together a text based on the inter-sessional discussions. We want to present it for Member State comments and stakeholder comments, whether it meets what we want to do or if we want to make any changes, any comments, additions, subtractions. we are able to do so. And so with that I'll open the floor. I believe that Georgia Georgia please. There's no one in the Georgia seat, so. Or do we accept it as it is? I'm not getting any feedback. I would be happy because I want us to move quite fast. As the oceanial say, go in. Go in. So that means, okay, India, please. India [20:24]: Yeah, thank you, Koli. Before you said gone, I had to get in, even if I didn't have anything to say. How can you have it so easy? So this is just a small point. In general, we are fine with the text and the way it is written. There is just one, this one sentence that has been added at the end of paragraph one which says that now it says that in each case under procedures to be specified in future protocols or other instruments. Now, the question is around this phrase other instruments. Now, this, I don't know, it's just a thought that came to mind that do we see this as as problematic, or it would suffice to say under procedures as may be agreed or things like that. Because when we start saying other instruments, there may be questions as to what instruments are we talking about. So that was just one suggestion that came to mind. And we also remember that during the intercessional period, there was this discussion as to what, how many, you know, from A to F, how many, how long this list should be. Should it be a long list or should it be a short list? So that's another thing that do we want to write in things like simultaneous tax examination, tax examination abroad, because these are all subjects of another protocol that we are developing. So do we want to be very specific over here or just write only that which is essential? That's one. And the second point here is that A says exchange of information. In one of the earlier iterations, it said exchange of information in accordance with Article 10. That time it was 10, now it is Article 11. Do we want to restore that language because if if I -- and hopefully we will have an article on exchange of information so that we make clear that the exchange of information we are talking about is that exchange of information and not something else. So these are a couple of thoughts that came to mind. Thank you. Co-Lead · Khalid [22:55]: Thank you. Any more comments, please? Okay. Zambia, please. Zambia · Africa Group [23:11]: Thank you, thank you Chair and good afternoon. Some initial comments on Article 10 on behalf of the Africa group. The text generally we are in support of it, just a few minor changes. In paragraph one, where we have state parties cooperate to promote, it's our suggestion that probably We strengthen this by saying state parties shall promote mutual administrative assistance and everything we are in support of it. Just after paragraph F, the issue that Inge raised as well, where we have in each case under procedures to be specified in future protocols or other instruments, it's our view that probably this can be neat if this was dealt with as a separate paragraph, it can sit can see it as paragraph three and it can be redrafted to read the state parties shall develop guidance protocols or additional instruments as may be necessary for the effective implementation of these articles. So in terms of additional instruments it's only those depending on what the issue is that may be necessary but otherwise it would be important to just have guidance or protocols in how we facilitate countries facilitate the various forms of mutual administrative assistance that are listed in there. I think for us, the listing is still okay, so that at least we know the various forms that we are talking about and having also F that this is not limited to what we have. In terms of the point by India, we note that the previous text actually had reference exchange information in accordance with the art connections information and I think it's something that can be considered to be put there. Then as regards paragraph two, whilst we appreciate where this is coming from, it seems that it might still be ineffective or a bit redundant depending on how member states interpret it and because it doesn't seem really to have a strong commitment when we say the member states shall identify barriers to effective mutual administrative assistance in tax matters, then we say and cooperate to eliminate if and as appropriate. Member states may, what will really make member states to say this is appropriate or this is not appropriate seems to bring in some ambiguity. And therefore we think the previous text that we had with a bit of a minor adjustment where we say the state parties shall identify and eliminate administrative barriers that prevent effective mutual administrative assistance in tax matters. We note that in the current text, we just have identifying barriers, but there's no commitment to eliminate such barriers and we think it's very important. that that is taken into account if we need to achieve effective international tax cooperation in this regard. And therefore, we think the previous text, which are the word eliminate, should be considered. And in our written submissions that we shall be making, it's our submission that we should still reinstate the issue of eliminating any administrative barriers. But it's also key that these are also identified by member states. I submit. Co-Lead · Khalid [27:02]: Thank you. United Kingdom, please. United Kingdom of Great Britain and Northern Ireland [27:06]: Thank you, Khalid. The UK, of course, and we've said this a number of times, supports the inclusion of high-level principles relating to mutual administrative assistance and transparency, as the following article will cover. I think we still have a fundamental question though, which we've asked a number of times on this article, which is about how this relates to existing instruments and how it interacts with that. I think it's our view, and I think obviously this relates to the MAC, I think it's our view that. The framework convention should complement and augment existing mechanisms. And so I think we still need to understand how these existing mechanisms sit alongside these articles. particularly, and again, I think this is a question we would raise on the exchange of information article as well, what is the intention of this article? Do you see instruments like the MAC as being able to be a realization of these principles? I think this is really important and this I guess maybe is a case where something like an explanatory note. Would help us with our understanding of this and I certainly don't think yet simply reading Article 21 and this together gives us that comfort. So I think we would again. We've asked for this before, but I think again, we would ask for some explanation. About how these articles, where there are existing deep instruments of cooperation, whether those are intended to realise these principles or not, or if this is intended to provide the legal basis for that. So I think that would be helpful to us. Thank you. Co-Lead · Khalid [28:40]: Thank you. Russian Federation. Russian Federation [28:46]: Thank you very much for giving me the floor. First off, we'd like to thank you for the work that you've done in preparing this article. Many comments that were made in the discussion have been considered. But we would like to speak in the spirit of the statement delivered by India and partially by Zambia in saying that the list of measures here is somewhat superfluous. That's because part of these mechanisms indeed are not applied by all states. So we would propose either thinking about deleting them from this list or decreasing the level of commitments like show, cooperate, and promote. On the whole, we support the current version of the article. Thank you. Co-Lead · Khalid [29:53]: Morocco, please. Morocco [29:58]: Thank you. First of all, I would like to say that Morocco fully supports the submission made by Zambia on behalf of the African group. And in particular, I would like to highlight one thing, the fact that when reading paragraph one, we have the end of the paragraph, we have including through, so we have, when we have including it, understood that it's non-exhaustive list. But at the end, the last item, we have any other form of mutual administrative assistance. So here we are just closing the loop. So it seems that becomes exhaustive. So maybe we could remove including in this case. So one other thing is when you look at the last item, F, we have any other form of mutual administrative assistance as may be agreed by the state parties from time to time. It doesn't say that it will be agreed through the protocol. or the format of that agreement, but we don't have it here. And then we have in each case and the procedures to be specified in future protocols or other instruments. So that gives the sentiment that the protocols will just take care of the procedures, just specify the procedures of the implementation of each of the items. And we believe that protocols would need to do more than that. And for this, we strongly support the suggestion made by Zambia on behalf of the African group to have a third paragraph that would solve this issue and clarify what we have in the protocol beyond the defining of the procedures. Thank you. Co-Lead · Khalid [31:48]: Thank you. Switzerland, please. Switzerland [31:53]: Many thanks, Mr. Kolehmainen, and dear members of the Secretariat for having redrafted this provision. It goes in the right direction, in our view, in the direction of high level language, but as often when we see new language, I'm afraid we have questions to ask. Our main question concerns the relationship between the obligation to engage in the mentioned forms of mutual administrative assistance according to the Framework Convention and the procedures to be specified on the protocols to the Framework Convention. The question is therefore, are all of the mentioned forms of mutual administrative assistance mandatory for signatories of the Framework Convention? since no reservations can be made according to Article 25 of the draft framework convention? And if yes, do countries then have to sign the respective protocols containing the procedures to be followed for respective type of assistance? Or will member states still be free not to sign a protocol, as is implied by paragraph four of article 20, and must therefore not necessarily engage in a form, in a concerned form of mutual administrative assistance? Mr. Kowalick, we would like to receive more indication on this issue in light also of the circumstances that some of the mentioned forms of mutual administrative assistance collide with our policies and constitutional limitations in general. And furthermore also the acceptance of forms of mutual administrative assistance depends largely also on the procedure to be followed. and we could not adhere to a convention that creates obligations in that field whose procedural details cannot sufficiently be anticipated. Mr. Kohli, with all respect, I would like to address this question in the first place to you. Of course, we are also interested in learning what other delegations think, but as a starting point of the discussion. I think it would be helpful if you could provide us with your interpretation since it is your proposal. And finally, we believe that the easiest way to provide countries that have the same uncertainties as we do with the necessary comfort in respect of mutual administrative assistance would be to allow reservations regarding this provision. Let me be clear, we believe this would be indispensable otherwise a certain number of countries would not be in a position to adhere to the framework convention as it stands now. Thank you. Co-Lead · Khalid [34:52]: Thank you. And let me clarify. I think I've said this several times before and I'll say it again. The draft is based on presentations made by member states. It's an attempt to capture what we have said or what we have provided in writing. And so it's been given back to members to affirm what is there or say, no, this is not what we said. This is what we said. Change it. Read this. So I'm not the one to answer the question you are raising is for member states to answer what do you want in the document? And that is what we'll put in the document. So it comes back to Member States to answer those questions. When it comes to notes and other things, we are discussing it and we talk to each other in the intersession, we explain our points. I don't think that it's possible for us to capture all those explanations and put them that. That's why we have the written comments. And so I'll repeat. these questions belong to Member States to answer and to come out with what they want to come with at the end. Thank you. Germany, please. Germany [36:20]: Thank you, Mr. Kooleit. Germany also welcomes the shift in the draft towards a higher level language. We also welcome the clarification that future protocols or other instruments will specify the detailed procedures. At the same time, we share the concerns that were just expressed by our distinguished delegate from Switzerland regarding the interplay between this commitment and the respective protocol and whether paragraph one of the current draft undermines the optionality of future protocols. In our view the provision should more explicitly recognize that existing multilateral instruments already provide comprehensive frameworks for administrative assistance. The convention should build upon existing mechanisms rather than establishing parallel legal obligations, which is why it is important for us that the reference to other instruments is kept. In our opinion, this reference should be understood to include reservations and limitations already provided for in notifications to such existing instruments for administrative assistance. This approach, we believe, would also address the concerns raised by other delegations regarding the fact that not all member states have implemented or are applying all of the measures that are being listed in the article to the same degree. Thank you, Mr. Goleet. Co-Lead · Khalid [37:55]: Thank you. China, please. China [38:00]: Thank you, Colleague, for giving this floor. We recognize the necessity and importance of mutual administrative assistance while taking into account the practical. Needs of the states as well as the limitations imposed by relevant domestic and international laws and regulations. The modalities from sub paragraph A to sub paragraph F in paragraph one of mutual administrative assistance produced provided in article 10 are not readily realizable or even. Attainable under the national laws of certain countries. This brings us once again to recognize the importance of article 25. Should specific reservation clauses be absent, the inclusiveness of this convention would be compromised for the reasons set out above. Additionally, whether to adopt a protocol should follow certain procedures and rules in accordance with this convention. So the sub paragraph in each case and procedures to be specified in future protocols. Or other instruments seems to be out of place. Later, we will submit our written comments. Thank you. Co-Lead · Khalid [39:25]: Thank you. Israel, please. Israel [39:30]: Thank you, Chair, and thank you for the rewarding. I want to say that, like Germany and Switzerland, there is a treaty, an agreement on this subject, an agreement that more than 150 states are signed to. And I think that we should -- we don't have enough time, so we should use that agreement, maybe just deal with the gaps and make sure that we deal with them and not try to invent another treaty in the time that we don't have. I want to say the interaction with other agreement like UK said, it's something that we want to know what will happen, how we will deal with that. And like Switzerland said, the reservations, at the MEC we have reservation and most of the countries did have reservation for certain issues in the treaty, in the agreement. And I think that if we will have reservation, there will be a broader acceptance of the, I'm not sure, it's not the convention, it will be through a protocol maybe, but there will be a broader exception. And something more that is very important for us is that like India said, we are dealing on a higher level, but still there is a lot of criteria are mentioned here and I think that the secrecy, the criteria should also be here because we have to save the details of our, of the of the taxpayers. We cannot, if we give another country the information, they have to save it. Let's say there should be agreed criterions how to save this information because if there will not be a criterion for that, or criterions, then I don't see how in every exchange we should add an explanation how to do it, how to exchange, how to save it. I think it should be said, it should be agreed upon a set of criterions that will make it able to exchange information much much faster and without so much administrative cost to it. Thank you. Co-Lead · Khalid [42:38]: Thank you. Saudi Arabia, please. Saudi Arabia [42:42]: Thank you, Mr. Khalid. I think this question was raised before, but when we talk about the list, we're not clear how the draft proposes to handle the specific forms. of assistance listed such as assistance in tax collection and simultaneous tax examination given that these obligations may be absent from many bilateral agreements and may exceed the legal or administrative capacities of various states. And if such list is retained, I think we agree with our distinguished delegates from Morocco that the list read as exhaustive and therefore suggest using may include provided it is explicitly understood that any such measures require mutual agreement between the state parties. Thank you. Co-Lead · Khalid [43:45]: Thank you. Chechnya, please. Czechia [43:49]: Thank you, Mr. Cody, for giving me the floor. Czechia supports mutual administrative assistance in tax matters and welcomes the shift to the more high-level language of the provision. We share the concerns expressed by the distinguished delegates from the United Kingdom, Switzerland, Germany, and Israel regarding the relationship to other instruments. like to support the interpretation of paragraph one that states parties of the framework convention are not obliged to sign any protocol based on article 10 as mentioned by the distinguished delegate of Switzerland in addition we would also like to support the possibility to make the reservations to this provision as mentioned by other distinguished delegates uh we would also like to understand the relationship between letter A and article 11 perhaps letter A is redundant if article 11 stays in the convention. And then we would also like to flag that the use of the word support domestic resource mobilization can be a little bit extensive when compared to other current instruments. So we also might send a written comment regarding this language. Thank you. Co-Lead · Khalid [45:01]: Thank you. Singapore, please. Singapore [45:06]: Thank you, Khalid, for the revised draft. Just two points. I think we echo the comments made by Switzerland, Germany, China, and Saudi Arabia that the language in paragraph one appears to create an obligation for member states to engage in the specified measures listed in subpara 1e. To f. This would limit participation in the framework convention as many members have constitutional constraints on some of these measures. And the ability to make reservations are not currently provided for in the framework convention. So we would support the. Suggestion by Saudi Arabia to replace the term including through with the term which may include to encourage participation. Alternatively, as I think suggestion was earlier made to specify this list and the relevant details. And procedures in a protocol instead to preserve the optionality. And lastly, we also echo the points made by the UK that we do need to find and identify the gaps and if possible rely on existing instruments such as the MAC to fulfill some of these obligations. Thank you. Co-Lead · Khalid [46:14]: Thank you. France, please. France [46:18]: Thank you, Chair. At the outset we wish to welcome the work done on this article. It is moving in the right direction in our view and is in harmony with the nature of a framework convention. We share the comments that have been made by the UK and German colleagues and also by others about the need to take into account existing instruments. We won't repeat those comments, we fully endorse them. However, we do wish to more specifically emphasise something under paragraph two, and more specifically the barriers therein referred to. We wish, in order to give a truly enlightened response. We want to know what's alluded to by this stipulation. We can't commit to a text whose scope is not clearly defined. If we do not receive clarifications on what's aimed at here, it seems that the only possible way forward would be to delete this article. It is in somewhat redundant if it's not targeting something in particular. it's redundant, it overlaps with the first paragraph if it doesn't target something else specific. So we need more clarification to have further discussion. Thank you. Co-Lead · Khalid [47:33]: Thank you. Austria, please. Austria [47:37]: Thank you, Colleague. We really appreciate the work that you and the Secretariat have done improving the drafting of Article 10. We can agree that we're moving in the right direction. We do think it would be important to exchange the word shall cooperate to promote to shall cooperate to enhance in order to highlight and reflect that there are already existing frameworks that enable mutual administrative assistance in tax matters. We therefore echo all the delegates that have previously adhered or referred to that, especially from the UK, Switzerland, Germany, Israel, and France, and I will abstain from repeating this point. However, against this backdrop and in the context of paragraph two, we would like to reiterate that collecting data and analyzing existing administrative barriers, as we've mentioned in the past, is of utmost importance because it could form the basis of an informed discussion about possible solutions. Only when we are aware of these barriers, we know what we're actually trying to to address with this article. We are also of the opinion that in line with providing a high level commitment of the framework convention, the list in paragraph. One should be deleted. We also echo China and Israel and others that have suggested to allow for reservations to increase the probability of adhering to the framework convention. Thank you. Co-Lead · Khalid [49:04]: Thank you. UAE, please. United Arab Emirates [49:09]: Thank you, Khalid. The UAE highlights the extensive cooperation already taking place in this area and stresses the importance of avoiding duplication, which could create unnecessary legislative and administrative burdens. Like other delegates mentioned, we believe that further clarity on how this article would interact with existing agreements and tools would be helpful. Given that many member states have lodged reservations on assistance and collection of taxes under existing instruments and considering constitutional and resource constraints, assistance and collection of taxes could either be excluded or made optional with the possibility of reservations. The examples given in A to F should be moved to a protocol as they are too prescriptive and could be incompatible with constitutional limits. We note that Article 21 of the draft convention encourages the progressive alignment of existing international agreements with this convention and its future protocols. When read together with Article 10, there is a risk that states could be understood as being expected to revisit existing treaty arrangements in order to expand forms of administrative assistance beyond those previously agreed. The UAE would therefore favor language making clear that cooperation under Article 10 is implemented in accordance with applicable international agreements, domestic law, and mutual agreement of the states concerned. This would preserve legal certainty, avoid duplication with existing treaty frameworks, and ensure that the convention complements rather than reshapes the existing international architecture for administrative cooperation. Thank you. Co-Lead · Khalid [51:03]: Thank you. Estonia. Estonia [51:09]: Thank you. Estonia believes that exchange of information, mutual administrative assistance and the effective prevention and resolution of disputes are the key to success to international tax cooperation. However, We also believe, like Israel, that perhaps due to the time constraints that we have, we should at least in the beginning rely on the existing instruments, namely the mutual administrative assistance convention that has quite big uptake and perhaps because it does allow the reservations. Although we are able to provide international administrative assistance, we also recognize that there are many countries also in this room who may not have this possibility either for the time being or perhaps forever. So if we are to have this article here, then we also believe we should have the possibility to make reservations and not to have such a firm and final commitment that the word shell will give in this text. Thank you. Co-Lead · Khalid [52:31]: Thank you, Senegal, please. Senegal [52:38]: Merci. Thank you very much, co-lead. I wish to echo comments made. by the African Group but also the comments made by Morocco. As regards paragraph 2, as the African Group has underlined, I think the word "as appropriate" could be appropriate here. We know that there are barriers that are an intrinsic part of administrative assistance as currently provided, barriers also include the interpretation of certain principles here. In practice, a number of countries have submitted requests for information, but they found that the response they've received was that the principle of credible similarity has not been respected. So what do you have? There's just one alternative left, that is to wait for the assessment made by the jurisdiction to then come back with comments. But of course, this doesn't, in general terms, come with positive financial implications because you don't receive the information you need to really provide an accurate assessment. So that's one of the limits presented by the fact that this presented and that's what this convention could seek to remedy. So we're not trying to reinvent the wheel. There are good components that should be built upon, but there are vacuums, shortcomings, and we need to flesh these out. Now something else to be considered is that Article 10 refers to mutual administrative assistance. The goal of the convention is to have a convention that strengthens international tax cooperation. Are we really able to talk about international tax cooperation if we ignore administrative assistance? No. So what we're talking about is a high level commitment because of course the answer to that question is no. So what we need is a high level commitment and given that there is should be this high level commitment, the implementation should be obligatory because this is a fundamental component of the convention. In my view, this is why if you look at the proposal made by the African group, that is to insert a third subparagraph, one that in its substance would support the idea that states should develop tools and guidelines that would foster effective implementation of this article's provisions. So We're only kicking work off here, but there are other instruments which should follow suit, of course, and as they do follow suit, already existing practices cannot be overlooked or blissfully ignored. Something else I'd like to say is that there would be added value to this convention if we ensured that mutual administrative assistance was followed up on. So, we need to have a legal instrument that acts as a legal basis on which to provide mutual administrative assistance. There needs to be this legal foundation for mutual administrative assistance. Of course, rules pertaining to confidentiality, privacy, other things that have been underscored by other delegations will of course be complied with by provisions that will subsequently be developed. So they were the comments that I wish to share and I wish to thank you, co-lead. Co-Lead · Khalid [56:32]: Brazil, please. Brazil [56:39]: Thank you, Mr. co-lead. We support mutual administrative assistance in tax matters. In paragraph one, we propose replacing the list of specific forms of mutual administrative assistance with a general provision for states parties to afford one another mutual administrative assistance in tax matters. The specific modalities of cooperation would be developed through protocols or other instruments agreed by states parties, the states parties. This approach provides the flexibility needed for the framework to evolve over time and places all forms of administrative cooperation on an equal footing, allowing future protocols to reflect different levels of commitment and technical developments. With respect to paragraph two, we propose streamlining the text by focusing on cooperation to identify and eliminate administrative barriers that hinder effective mutual administrative assistance in tax matters. Thank you, Mr. Khalid. Co-Lead · Khalid [57:53]: Thank you. Sweden, please. Sweden [57:58]: Thank you for the opportunity to speak. We appreciate the In general, we support mutual administrative assistance. We appreciate the efforts from the co-lead and the secretariat to updating this article. And we especially appreciate the change that has been made in the first paragraph to focus more on cooperation. In our view, we have similar concerns that several member states already mentioned, a commitment on mutual administrative assistance should be kept more general and the article should be drafted so that all jurisdictions would be able to fulfill the commitment. We believe that any details such as the list should be developed in a future protocol also because it would be more flexible. In this context, I would also want to highlight paragraph 22 in the terms of reference that states that we should consideration the work of other relevant forums. Thank you. Co-Lead · Khalid [59:05]: Thank you. Japan, please. Japan [59:10]: Thank you, colleague. We are aligned with the UK, Switzerland, Germany, and others that this article should aim to compliment. Or improve existing frameworks such as MAC. To ensure effective international cooperation, it is important to avoid overlap or conflict with existing frameworks. And this article should outline only high level principles that international cooperation is essential in mutual administrative assistance. Regarding paragraph two, We should note that certain safeguards, such as information protection measures, confidentiality, and data safeguards must be met for effective cooperation, and such safeguards should not be viewed as barriers. We also support for the reservations. Thank you. Co-Lead · Khalid [1:00:02]: Thank you. Please. Algeria [1:00:10]: Thank you, colleague. At the outset, we wish to support these statements made by Zambia on behalf of the African group and by Senegal and Morocco. We fully support the insertion of an article on mutual administrative assistance and the proposals, the wording proposed for the article. However, there's something that I want to add into the wording that's been proposed. This is for paragraph 2, where parties shall identify barriers to effective mutual administrative assistance in tax matters and cooperate to eliminate them if and as appropriate. This wording could transform an obligation to identify and eliminate something to one with conditions attached. And there the effective eradication of barriers becomes optional, so we would insert something else to make it clear that States parties must establish guidelines, additional protocols that are necessary for the effective implementation of that article. That is an attempt to ensure that these obstacles are in fact removed. Thank you, co-lead. Co-Lead · Khalid [1:01:28]: Thank you. Denmark, please. Denmark [1:01:32]: Thank you for giving me the floor, Mr. Kohli. I will be rather short in my intervention. Denmark supports mutual administrative assistance in tax matters and we welcome the development of this article and the movement that has been made in it. That being said, we share the sentiment expressed by multiple delegations on the floor today of a risk of duplication of existing instruments and the need for seeking clarity of how existing instruments should interact with this article in the Convention. And with that, I will stop now. Thank you. Co-Lead · Khalid [1:02:11]: Thank you. Belgium, please. Belgium [1:02:18]: Thank you, co-lead. We can... I will be very short and echo what the distinguished delegate of Denmark just said and also add that we are in line with the fact that, concerning mutual administrative assistance, there should be a possibility to make some reservations because assistance in the recovery of tax claims tax claims with respect to particular categories of taxes might also be very difficult to achieve. And so in some instances, it seems like a reservation on this article should be a possibility. And the fact that currently Article 25 just says that there is no room for any reservation, I think there are a lot of other UN conventions where there is still a possibility, albeit limited sometimes also, or in specific or regarding specific articles, that there is a possibility to make reservations. That is something we have to take into account. We also want to refer to the intervention made by the distinguished delegate of Austria, and we would align itself that to put enhance cooperation shall enhance cooperation in paragraph one seems like a good way of expressing that there are already 150 countries who have who are part of or party in a mutual administrative assistance convention not saying that there are no gaps But I think it's very important that we stress it here because it is not an easy subject to make sure that it happens in every instance. So thank you. Co-Lead · Khalid [1:04:07]: Thank you. Nigeria, please. Nigeria [1:04:12]: Thank you, colleagues. And good afternoon, colleagues. I think now that the there has been very good support even from all the delegations regarding this article I see that there's an agreement that we need to cooperate Mutual assistant administrative assistance um uh amongst ourselves so uh if that is the case I think we should therefore allow this commitment because this is a commitment to cooperate how we're going to do it our understanding is that that will be flexed out in the protocols that will be developed. So whatever issue that we are discussing around existing instruments, I believe that the protocol is maybe the appropriate place where we can be having such discussions. And I also want to state that existing instrument that we refer to I know that a silos of them and you know not a single one has been able to bring all of us together under the same umbrella. So if you leave out others, in engineering they say you are only as strong as your weakest link. So this commitment will enable every other person, every other jurisdictions to come under that umbrella and will be able to operate as a united front. Having said that, I also need to emphasize that Nigeria aligns with the position canvassed by Zambia on behalf of the African group and also by other colleagues that have spoken ahead of us. We want to particularly stress that all of those amendments that have been proposed by the African group, we are in support of it. And by the time we send in our written comments, I think we'll be able to look at it in greater details. Thank you, Chair. Co-Lead · Khalid [1:06:26]: Thank you. Republic of Korea, please. Republic of Korea [1:06:30]: Thank you, Mr. Collett, for giving me the floor. Korea recognizes the importance of mutual administrative assistance in tax matters. Having said that, we align with the views expressed by Singapore, the UAE and others that the provisions in paragraph 1a and f remain prescriptive and would be more appropriately addressed in the future protocols rather than in this convention itself. Regarding the relationship with existing international instruments, We also support the comments made by multiple delegations, including Israel, UK, Germany, and others, on the importance of ensuring consistency with existing frameworks and avoiding unnecessary duplications. In this regard, we align with a comment made by Austria and Belgium, changing the word in paragraph one, shall cooperate to promote, to shall cooperate enhance. with your administrative assistance. Lastly, we also note the comments made by other delegations, including China, Israel, and Japan, regarding the possible role of reservations in enhancing the accessibility of this convention. Thank you very much. Co-Lead · Khalid [1:07:58]: Thank you. Philippines, please. Philippines [1:08:03]: Thank you, Mr. Co-Lead. We appreciate the preparations done in redrafting this provision. We are amenable with a more general rewording of paragraph one, but echo the concerns of our colleagues on the level of obligation this imposes on all of the parties. A number of us do not all implement all the forms of mutual administrative assistance because of legal and resource constraints. So we are amenable to looking at the rewording suggested earlier to make the article more proportionate to capacities. and the legal frameworks that we have, non-intrusive and more flexible. Thank you, Mr. Co-Lead. Co-Lead · Khalid [1:08:42]: Thank you. Cameroun, please. Cameroon [1:08:50]: Thank you, Co-Lead, for giving me the floor. I wish to begin by supporting the position of the African group as expressed by Zambia. I also wish to echo what was said, the comments and the proposals made by a number of delegations, namely Nigeria, Morocco, Senegal and Algeria. Cameroon wishes to make a number of brief wording suggestions for Article 10. It's a very important article. because it is one of the articles that will make it possible to really give tangible form to this international tax cooperation that we're trying to bolster. Our first wording proposal would be as follows. Paragraph one, we simply wish to suggest perhaps replacing the expression cooperate to promote with an expression which might be more compelling for states. States must commit to participating in a mutual administrative assistance mechanisms. They must participate and implement mutual administrative assistance. So this type of phrasing would really ensure that states did commit to doing just that. The term cooperate doesn't really seem strong enough to us. Now, Mutual administrative assistance is referred to here, and this is my second proposal. We talked about the administration of taxes, the fight against tax evasion and avoidance, the mobilization of revenue, all of this is important, but I think that the primary goal of this mutual administrative assistance is the implementation of tax legislation more broadly. So we want to incorporate that goal, that is, we want to ensure that there is mutual administrative assistance in order to facilitate the implementation of fiscal legislation, the administration of tax and the combating of fraud and illicit financial flows. So the second proposal would be for paragraph two and a kind of sub para, we would propose adding In addition to this engagement to identifying barriers and obstacles to mutual administrative assistance, we would add here that states should commit to adjusting their domestic legislation to ensure that this mutual administrative assistance is both facilitated and is effective. Thank you. Co-Lead · Khalid [1:11:42]: Thank you. Kenya, please. Kenya [1:11:47]: Thank you, Chair. We align with the submission made by Zambia on. Behalf of the Africa group, as well as the submissions from Morocco, Senegal, Nigeria and Algeria. We support the proposal to move the reference to protocols away from the listing in paragraph one and to give it a standalone paragraph, as proposed by the Africa group. We also support the redraft of paragraph 2 to delete the conditionality at the end, which is if and as appropriate, so that we ensure that the barriers are actually identified and eliminated. As we said earlier this morning, the mandate of this committee is to establish fully inclusive and effective international tax cooperation, a standard which the existing mechanisms and frameworks do not meet because not all the countries in this room are involved in their development. We therefore don't support any outright conformity with such mechanisms. The committee is well guided on the approach of taking them into consideration during this work. Thank you, Khalid. Norway [1:13:07]: Thank you, Mr. Koelid. Thank you for providing this redraft and also taking some of our suggestions from the last session into account. This is much appreciated. Mutual administrative assistance is a cornerstone of international tax cooperation. Given the broad cooperation that already exists in this area and the wide participation of Member States in this existing framework, we think that Member States should be allowed to comply with this obligation through that framework. Going forward, we should make sure to preserve the optionality of protocols and respect the limitations that jurisdiction have indicated that they have with respect to some forms of cooperation in the list. We recognize this list in paragraph one from the MAC and in general we agree that they are all relevant and we engage in these forms of cooperation without a lot of restrictions in our country, but We respect that other countries have these limitations. And we also note that in the existing frameworks, terms are set out on how to cooperate, that that provides clarity on how to do it. And we don't think that there is a need to replicate or create parallel structures here. We think maybe changing the wording in paragraph one to may include could help here. And the possibility to make reservations seems necessary to ensure broad participation. Now, with respect to paragraph two, we agree that all countries should benefit from mutual administrative assistance. And we acknowledge that the ability to make use of the existing framework is uneven. We should therefore explore how we can meet those challenges so that improvements can be discussed and put forward in the relevant forums. A fundamental question here when dealing with the barriers we want to overcome is to have more clarity on what they are. They could be legal barriers, they could be practical or technical barriers, or they could be a combination of all of this or something else. So we've had discussions regarding this in previous sessions, and it would be really useful to get some concrete examples of where the current frameworks does not work so that we can better understand and work on these issues. So thank you. Co-Lead · Khalid [1:16:07]: Thank you. Mauritius, please. Mauritius [1:16:11]: Thank you, Khalid. I think on this article there's general agreement as to having such a provision on mutual administrative assistance. In terms of, let me just mention that I'm in full support of what has been proposed by the Africa group. related by Zambia and other countries that have spoken before me. So in terms of improvement, in terms of reinforcing the provision, I think instead of the word cooperate to promote, we could replace them by the words extend to each other mutual administrative assistance. In terms of the list, whether we have an exhaustive or a non-exhaustive list of means of extending the assistance, probably a non-exhaustive list allows us to include matters which at this point in time we are not thinking about. When it comes to tax collection, we all know that probably having recourse to the powers that the tax authority have under the domestic law is something which is appreciated and probably needed. As regards reference to the development of future protocols, I think it would be needed to have it in a separate paragraph. And then barriers to effective mutual administrative assistance need not only be identified but also eliminated. And I would tend to align myself with what has been mentioned by Brazil. We could just mention that the state parties shall identify and eliminate barriers that hinder effective mutual administrative assistance in tax matters. and stop it there. Thank you. Co-Lead · Khalid [1:18:24]: Israel, please. Israel [1:18:26]: Thank you, Chair, for giving me the second time the floor. I just wanted to say regarding sub-paragraph f that the previous wording was at the end through protocols and other instruments. And As it is now, it's like an open commitment, but we do not know what does it say, what we are committing to, and it's a problem, it will be a problem for us to explain that to our government. Something that we need, it will be something that needs ratification, so it will be if we want to add something, we need a protocol or other instrument that needs to be ratified. Otherwise, it's like open something that we are signing to something that we do not know what it is. Thank you. Co-Lead · Khalid [1:19:28]: Cambodia, please. Cambodia [1:19:31]: Thank you, Chair, for giving us the floor. And Cambodia also fully support Article 10 regarding the mutual administrative system. However, we would like to echo the concern raised by the UAE, the Philippine and a number of distinguished delegation and their respective administration citing constrained domestic legislation, resources and capability. So Cambodia is also aligned in the point raised by distinguished delegation from China and other in term of keeping this article high level Yet terms that signify binding or prescriptive in following measure either from the existing mechanisms such as MAX or the framework event should be more generalized. And Cambodia also would like to have the possibility of reservation as raised by the distinguished delegation from Japan, South Korea and Norway. Thank you. Thank you, co-chair. Thailand [1:20:38]: Forgive me the floor. Thailand support the objective of strengthening mutual administrative assistance in tax matter. However, we would like to echo concern expressed by India and Singapore and other delegate. As for the different capacity, legal framework and the level of readiness of each country, it is crucial to take this matter into consideration when implementing mutual assistance mutual administrative assistance. So we think that we support the idea that we should delete subparagraph a to f and keep it at the high level. Thank you. Speaker 65 [1:21:23]: Thank you, Chair. Thank you, Mr. Co-lead for give me the floor again. I just quickly wanted to join Norway in asking member states and identified concrete gaps and issues with the current system to raise these issues with concrete examples so we can make sure that the text of the convention and any proposed solution can solve these issues. We also wanted to echo Austria and others in considering using the term enhance instead of the word promote. Thank you. Co-Lead · Khalid [1:21:55]: Spain, please. Spain [1:22:16]: Thank you, Mr. Co-Leader, for giving me the floor. Spain is in agreement with mutual administrative assistance on tax matters. We would like to echo what was said. specifically by Norway, the UAE, Singapore, France, Austria and other countries of the European Union. I won't repeat what has been said, but I have a question following a remark made by Turkey. It concerns an addition. to the first paragraph, which says that mutual administrative assistance in tax matters could be used to promote matters to support domestic mobilization of resources and to combat tax evasion. and avoidance. So my question is, would it be possible to specify what is understood by that? Could we move beyond mutual administrative assistance in tax matters? Could we conceive of requesting information for other purposes concerning issues other than tax evasion, that would be important to know exactly what we mean here. Because this idea is not a usual one, I'm not sure that it's mentioned in other existing instruments. Thank you. Co-Lead · Khalid [1:24:17]: Thank you. Ghana, please. Ghana [1:24:23]: Thank you, co-lead. Ghana aligns with a submission by Zambia on behalf of the Africa group, and as was supported by Morocco, Senegal, Algeria, Nigeria, Cameroon, Kenya, and Mauritius. We reemphasize that the mandate of this framework convention is to establish a framework that is more inclusive, since these existing systems that are referred to did not have all countries at the table when they were being developed. We are in support of the written input that would be made by the Africa Group on a proposed redraft of the article. Thank you, co-lead. Co-Lead · Khalid [1:25:02]: Thank you. Arlen, please. Ireland [1:25:06]: Thank you, Mr. Co-Lead, and to the Secretariat for the updated article. We welcome the new wording, which we believe is going in the right direction. To avoid too much repetition, I will note that we share the concerns expressed by Denmark, Germany, the Czech Republic, Estonia and the United Kingdom. We also support the comments of Cambodia, Belgium and others to find a way for states to make reservations. That will give us the best. Chance of ensuring that as many member states as possible are able to sign the convention. Thank you. Co-Lead · Khalid [1:25:44]: Okay, there were a few questions that came up and some requests for some background. What I would do is that I have a list of documents which we can go and refresh our memories on. I think the last itinerary is this UNAR is taking. So we have the Secretary General's reports. We have the resolution 74.244. 78.230, 79.235 in the terms of reference for this committee. I believe a reading of them will help us understand our mandate and some of the things that we form the basis for what we all are doing here. So with that, I'll invite INESC to speak, please. INESC · Latindadd + GATJ [1:26:40]: Thank you, Mr. Chair. I'm not used to. I'm from Inesc, Brazil, and I'm talking on behalf of Latin Dad and the Global Alliance for Tax Justice. Article 10 names the forms of mutual administrative assistance states party will provide one another, but leaves nearly all the substance for later. And what's more, for an issue as important as ensuring equity and inclusion across redictions, the language is weak. So we have the following comments. First, we note with concern that reference to affording one another the widest possible measure in paragraph one is missing. So we propose returning this text. Second, we are concerned with reference to the following, on the procedures to be specified in future protocols or other instruments. We believe that this should be replaced with a clear mandate to the Conference of Parties to determine what methods of mutual administrative assistance are required and the guidance standards for each. Third, we also bring to the attention that developing clear timelines for mutual administrative assistance is necessary. We know that many global South countries have experienced non reciprocal mutual administrative assistance assistance. We believe that the Conference of Parties can determine such timelines to ensure that mutual administrative assistance happens in a timely manner. Under the COP, a monitoring and reporting mechanism on mutual administrative assistance can be developed. Fourth, we miss a mandatory, not discretionary, barrier removal obligation. Paragraph two asks states only to identify barriers to assistance and cooperate to eliminate them if and as appropriate, rather than establishing it as a monitored obligation. Lastly, we believe that various forms of tax transparency, including automatic exchange of information, country-by-country reporting, and a proposed global assets register will be critical towards ensuring effective mutual administrative assistance. We note with concern that only exchange of information is included in this article. However, the other transparency mechanisms are missing. We continue to urge inclusion of these measures and propose that they be developed as standards alone articles. Distinguished delegates, for us, Article 10 should be strengthened to include an operation baseline, operational baseline that applies now, a transparency link to the convention's public reporting and asset registry proposals and a clear mandate for the COP, including a monitoring reporting mechanisms mechanism among other measures to be taken by COP. Thank you. Co-Lead · Khalid [1:29:33]: Thank you. African Union, please. AU [1:29:41]: Thank you, Khalid, for giving me the floor. The African Union aligns itself with the intervention delivered by Zambia on behalf of the Africa group and supports the proposals submitted by Morocco, Senegal, Algeria, Nigeria, Cameroon, Kenya, Mauritius, and Ghana concerning Article 10. We consider mutual administrative assistance to be a central element effective in international tax cooperation. It is particularly important for African countries which continue to face significant challenges when it comes to cross-border tax evasion and avoidance. We therefore support the formulation of Article 1, which recognizes that mutual administrative assistance should facilitate administration of taxes, combating tax evasion and avoidance, and support domestic resource mobilization. The explicit reference to domestic resource mobilization is particularly important. Mutual administrative assistance should not be treated merely as a technical process. It must contribute to the ability of state parties, particularly developing countries, to protect their tax bases, mobilize sustainable revenue, and finance their own development priorities. And I thank you, co-lead, for referencing the SG's report and other background documents provide the necessary information on this important link. The African Union further supports the proposal by the Africa Group with regards to the formulation of paragraph two. We also finally support the addition of a third paragraph which provides the development of guidance protocols or additional instruments where necessary for the effective implementation of this article which then takes care of the standalone sentence over there that says in each case and the procedures to be specified in future protocols or other instruments. co lead the African Union therefore categorically supports the Africa group's proposal in insincerity. We believe that the proposed text establishes a clear, practical and development oriented framework on mutual administrative assistance while preserving the sufficient flexibility for its future implementation and development. I thank you. Co-Lead · Khalid [1:31:56]: Thank you. TJN please. TJN [1:32:02]: Thank you. Okay, thank you so much Khalid for giving me the floor and I apologize for that. So I want to use my intervention to address some of the familiar complaints we keep hearing from the floor, in particular the claims of duplication with existing standards and the need to factor in existing work. So we consider the exchange of information and mutual administrative assistance. are both crucial to implementing almost every aspect of the convention. Yet we believe that as they stand, existing international instruments, and in particular the MAC, are not adequate to implement the objectives of the convention. And we can take the Article 6 on high net worth individual as an example. We know that inheritance taxes are one of the key tools countries have to tackle inequality. But under the MAC, exchange of information on inheritance taxes is optional, and many countries have entered into reservations against exchanging information on this type of tax. So countries would struggle to exchange information under this framework, even though there is near consensus that this is exactly the kind of tax that matters for tackling wealth inequality, which goes at the very heart of Article 6. And here I think we also should take this as a cautionary tale for countries use origin as to include reservations in this article. But then now some may say that we can reform the MAC and its related instruments. But it's not super clear how that would happen though. As far as I understand the global forum, which by the way does not include all UN member states, mostly administers and implements the norms. And it isn't really the place where legal texts get discussed or reformed. It is our impression that the power still seems to sit largely in other places of the OECD, including in Working Party 10, to which only three non-OECD UN member states are associates to. The governance of the Global Forum and its interaction with Working Party 10 is opaque enough that is really hard to understand how such reform process would work, and especially how could it ever be inclusive, which is the mandate that we have here. Call it a strong Article 10 is essential to give the Convention its legal, institutional and operational autonomy and to implement its objectives and commitments. Thank you so much. Co-Lead · Khalid [1:34:52]: Thank you. BCAS, please. BCAS [1:34:57]: Thank you, Co-Led, for the opportunity. Reference to future protocol is a unique feature of this article. It doesn't appear in other articles of the convention. And I thought, because this is to be decided in the future, this will be discussed very fast. But it still generated a good amount of debate and some countries did indicate that it will not be possible for them to sign the convention if this kind of articles are there. And that gives me some ideas as to how we can adopt overall approach for these negotiations. In the morning session it was said that we have limited time to finish the work and it should also be ensured that the maximum countries sign the framework convention. And to achieve this, a practical approach may be adopted by broadly dividing the articles in three categories. Category one, absolutely non-negotiable commitments by the countries. Now, these commitments are to be included in the framework convention itself. Protocol may or may not be required for such commitments. And the countries cannot make a reservation the convention or to the protocol if a protocol is created for these commitments. Category two, ideal to have commitments which would necessarily require a detailed protocol for implementation and that's article 10 which we looked at. Now for this kind of commitments only high level commitments to be included in the framework convention. Implementation will happen through protocol and a detailed debate can happen at a future date when we are negotiating the protocol. This is essentially, you know, pushing a debate, hard debate to a future date, which probably is not required. And the countries will have the option of not signing the protocol. And hence the countries need not hesitate to sign the framework convention at this stage, and the negotiation would be easy. Category three, ideal to have commitments which would not justify a separate protocol, so they need to be included in the framework convention itself. And then the countries can have an option to make a reservation on that particular article of the framework convention. Now this approach will ensure that the hard negotiations happen only on the issues on which it is required and happens only at the time when it is required. This probably will make the negotiations easier. Thank you. Co-Lead · Khalid [1:37:36]: Thank you. CEDD, please. CEDEAO [1:37:40]: Thank you, Mr. Chairman and Mr. Colleague. I speak for CEDD. We listened to the concern, duplication, capacity, flexibility. The draft already answer all three. First point, colleagues wants to move this article to the protocols. But look at the last word of paragraph one. It says the procedure will be in future protocols. So the article already does what you're asking for. The principle stays here. The machinery goes to the protocols. If we delete the article, we lose the foundation. The protocol will have nothing to stand on. Second point, flexibility. Article 20 says no state is bound by a protocol unless it joins it. So every state already has the choice. Reservation here will protect nothing new. They will only weaken the heart of this convention. Third point, duplication. Yes, an instrument exists with many parties, but instrument is by invitation. Many developing country are still outside of it. This convention is open to all. That is not duplication. That is extension to everyone. Last point, we support Brazil on paragraph two. Barriers identified should be barriers eliminated. We support Algeria and Zambia on the new paragraph three. Assistance between administration is not a risk. It is the purpose of this convention. Thank you, Mr. Chairman and Mr. Khalid. Co-Lead · Khalid [1:39:29]: Thank you. DMUN Foundation, please. DMUN Foundation · MGCY [1:39:33]: Thank you for the floor. I have the honor to speak on behalf of the Financing for Development Children and Youth Constituency of Major Group for Children and Youth. Tax administrations today confront taxpayers, assets, and transactions that move seamlessly across borders while their own powers stop at the frontier. No administration, however well resourced, can address cross-border evasion and avoidance alone. In an interconnected economy, mutual assistance must therefore become the default mode of tax administration, routine, reliable, and available to all, rather than an exception that is negotiated under a case-by-case scenario. Accordingly, Children and Youth welcome the progress that has been made on Article 10 and its open list on the forms of assistance. However, we must express concern that the current language promises cooperation pertaining to assistance rather than discussing concrete provisions that provide meaningful assistance. In this context, Children and Youth propose three adjustments to the draft article. First, in paragraph one, we call for the modification of the term promote to promote, provide, and enhance, confirming that the purposes of the article is not only limited to the encouragement but also the provision of assistance. Second, in subparagraph 1a, following the phrase exchange of information, we call for the insertion of the phrase including exchange on request and, where feasible, spontaneous and automatic exchange, providing a clear pathway forward towards the implementation of the article by setting foundational models to how such exchange of information can be created. Third, we call for an inclusion of a new paragraph following paragraph three that would state States parties should cooperate to support the capacity of developing countries to participate fully in and benefit equitably from mutual administrative assistance under this article, including through financial and technical assistance. Mr. Coleed, children and youth believe that with the appropriate modifications, Article 10 can serve as a dependable foundation for practical, inclusive, and durable cooperation that will uphold this framework's ability to carry out the structure outlined by the terms of reference. We thank you. Co-Lead · Khalid [1:41:51]: Thank you for Thank you for your interventions. I believe we can now move to article 11. And in article 11, which is the article on the exchange of information, if we recall, we had quite a number of clauses in other articles which talked about exchange of information. And it was suggested that we have a separate article for information so that we can bring all of them together, which we did. And through the intercessional sessions, we've sort of polished them a bit. And we now have this particular article. And so we would like to open it up for discussions and any suggestions that will help us to how to refine it. make it better for all of us. Thank you. So the floor is open. Okay. I think I have the pleasure of moving to article 12 since I don't see any request for the floor. Then people decide to. Okay, Colombia, please. Colombia [1:43:58]: Thank you, co-lead, for giving me the floor. Good afternoon to you and all colleagues. The first thing I wish to do is thank you and the Secretariat for your work, given that this is the first time I'm taking the floor. This exchange is very useful and has been indeed over the last few days. Co-lead, The general structure of the article is appropriate and in line with what's driven by the Convention on Mutual Administrative Assistance in Tax Matters as championed by OECD countries. The text incorporates elements which cover the goal and the scope of information exchange. Subpara b of the article on the exchange of information in terms of export and import control in order to detect and prevent illicit financial flows is key. This is B. This wording could extend to the use of information that is not tax related and could cover activities associated with customs, the oversight of external trade operations and the detection of trade practices which are fraudulent in nature. Subpara incorporates an express reference to assets and instruments that might have been used to circumvent the automatic exchange of information mechanisms. There needs to be a more preventive approach and one that tackles emerging risks in addition to traditional ones. as currently covered by the Convention on Mutual Administrative Assistance in Tax Matters. Paragraph 6 states that States Parties should bear in mind the needs and capacities of developing countries and countries in special situations. This provision is innovative and builds on the aforementioned framework because it recognises the existing differences between states in terms of technical, technological, institutional and institutional capacity in terms of implementing information exchange obligations. However, the text does not clarify the specific effects or purposes of all of this work. It doesn't elaborate on how there could be flexible mechanisms extended to those countries or the ways in which they could be provided with support. Thank you. Co-Lead · Khalid [1:46:39]: Thank you. Austria, please. Austria [1:46:42]: Thank you, Collete. Austria thinks that Article 11, as it's currently drafted, significantly differs from the structure and the drafting of the remainder of the Framework Convention. as it creates operational rules for the exchange of information, which clearly goes beyond a high level commitment as envisioned for this article in our opinion. We also recognize that the draft has not been recently amended compared to the draft circulated at the beginning of 2026 and therefore we wonder whether and why not why discussions that were had and comments that were received since then have not been reflected in the current drafting we would appreciate maybe if explanatory statements for that point could be including some elaborations on those choices Substantively, we continue to have significant legal concerns regarding the provisions on the exchange of information. These provisions require careful assessment to ensure their compatibility with constitutional requirements. Applicable data protection standards, as well as relevant obligations under supranational law. Therefore, we suggest deleting the article as it currently stands. This would also be in line with the TIR, which mentions exchange of information as a possible future protocol for states parties that are currently facing issues with existing mechanisms. Austria remains fully supportive of EOI as an important tool to combat tax evasion and avoidance, but we do not see the framework convention itself as an appropriate place to establish a separate legal standard. We do not therefore support a self-standing Article 11. We think the commitment as currently composed in Article 10 in the draft would be sufficient as an anchor for an operationalizing protocol or other instrument for states parties seeking this. Thank you. Co-Lead · Khalid [1:48:47]: Thank you. And I gave some background, and I think I need to give it to those of us who were not around a little while back. If we recall in Nairobi, this issue cropped up that we had several of these items in different articles. And the question came up as to whether we should move all of them to a single article or leave them where they were. Through the international sessions and through the other discussions, it was that we should create a separate article and move them from where they were into that article so that they work together, not separately. an issue cropped up yesterday and I think I will see it again that during the inter sessional sessions and as the suggestions come and comments come we synthesize them and put them together as reflecting what the majority would have said so the fact that somebody makes a comment or brings written comment or suggestions and it doesn't find itself into the text does not mean that it was disregarded. It just means that maybe it was not the majority view. And so I would like us to continue if we have comments as to something we want to change, let's say it. Thank you. Poland, please. Poland [1:50:12]: Thank you, Mr. Co-Lead. First, I would like to say that Poland fully supports the administrative assistance, especially exchange of information measures, which helps us to counter tax evasion mostly and the proper application of the tax treaties. Nevertheless, I would like to fully support what our distinguished colleague from Austria said, and I believe we should. Remove this article from the framework convention. So it doesn't fit to Article 10, for example, when we decide, I understand that this kind of provisions should be regulated by the protocols or other instruments, not convention itself. So I don't want to repeat all the arguments mentioned by our colleague from Austria, but please. I noticed that we would like to support deletion of this article from the Convention. Thank you very much. Co-Lead · Khalid [1:51:25]: Thank you. The Kingdom of the Netherlands, please. Netherlands (Kingdom of the) [1:51:30]: Thank you, colleague, for giving me the floor. Today, I have refrained from intervening up until this point because I hate sounding like a broken record. Like my Austrian colleague expressed, this is an operational provision. That provides for a direct obligation to exchange information for tax matters. Article 10 provides for a separate article on mutual administrative assistance and also includes the exchange of information amongst others. This serves as an appropriate anchor to provide for future protocols on the exchange of information. We are happy to exchange information with more than 152 countries in the world and we are also happy to enhance and improve that cooperation that has been established. This article may, for the reasons I just mentioned, be deleted in our view as well. Thank you. Co-Lead · Khalid [1:52:38]: Germany, please. Thank you. Germany [1:52:42]: Thank you, Mr. Kohli. Germany continues to consider Article 11 difficult to reconcile with the character of the convention as a framework instrument. We support the approach as taken under Article 10 by referring to different forms of mutual administrative assistance on a high level and then referencing instruments that provide for such mechanisms. Under that premise, We do not consider Article 11 a provision that is appropriate or necessary in a framework convention. We also do not view Article 11 as an alternative to having references to EOI in various individual provisions or commitments in the framework convention. Such operational provisions would be similarly misplaced. Regarding the content of the current draft, I refer to our interventions. during the fourth session as well as the numerous identical interventions made at that time. Thank you, Mr. Kholid. Co-Lead · Khalid [1:53:43]: India, please. India [1:53:47]: Thank you, Kholid. India was one of the first countries who had mentioned that we need a separate article on exchange of information. And the main reason for making that suggestion was that at that time, as the co-lead very rightly pointed out, the reference to exchange of information as a tool to achieve the objectives of the various other articles that form part of this framework convention were being referred to every article separately. And that made very inelegant structure and it created in our mind, a lot of redundancies in the text. And it was in that context that we suggested that there should be a separate article on exchange of information and that would then be the point of reference for wherever exchange of information was a tool to achieve the objective, whether that was for combating illicit financial flows or taxation of high net worth individuals or whatever it is. Now, we do understand that so many of us have committed to an exchange of information mechanism under some other organization, some other body. And we have consistently held this position that having a separate exchange of information article over here, does not at any point mean that we will abandon that work or we will step away from that. Even India cannot do that. Nearly 170 countries have members of, or more than 170 countries are members of the Global Forum. We exchange information as per the standards that we have all agreed over there. We have changed our laws. We have changed our practices. We participate actively in that and it is not our intention, at least it is not India's intention to step away from that. And by having an article on exchange of information over here, we do not see that as a signal that we will in any way step away from the work of the global forum. So I think having an article over here should not be seen as a threat. It is only to ensure that exchange of information the way we do it now will be a tool that we will use to achieve the objectives that we have set for ourselves under this framework convention. Now as regards the second point is as regards the structure of the exchange of information article that is over here. It is very detailed right now and it does not sit with the way the other articles have been designed. And We completely understand the point made by the co-lead that it is an accumulation of all the concerns that member states have expressed in the course of the various discussions that we have had so far. When we reconcile all those concerns, all those needs that member states have expressed in these discussions, probably this article does not need to be a simple accumulation of all that. All those concerns have to be synthesized. We will in time give our written input as to how we would suggest that this article should read. It has to be high level. It has to say that we will exchange information. And why will we exchange information? We will exchange information for the effective administration and enforcement of collection of our taxes, for the achievement of the objectives that we have set out, what kind of information we will exchange, in what circumstances we cannot refuse exchange of information, so on and so forth. So I think that is how we believe that structure has to be. Currently this article reads more like an article that would probably be bilaterally negotiated. So The short point for us is that one, we need an article, we need an article so that this framework convention is complete. And simply having a reference to exchange of information in the article related to mutual administrative assistance, to our mind, does not fulfil that completeness, that need for completeness of structure of this framework convention. And yes, probably this article as it stands, we would suggest a restructuring of it to align its structure and its reading with the other articles of this framework convention. Thank you. Co-Lead · Khalid [1:58:56]: Italy, please. Italy [1:59:00]: Thank you very much, colleague, for giving me the floor. Also would like to support the other delegates intervention relating to the opportunity to include an operational provision in the final convention. We have substantial objection in having such kind of provision, which also raises the issue of the interaction with existing similar provision in other instruments. And so from our perspective, this is not the proper place to have this kind of provision. We also have some relevant concern on some of the provisions included in particular in paragraph one of this article. We would object to the part, for example, from the concept of the foreseeable relevance, which is something considered a longstanding and crucial element for underpinning the exchange of information. And also the list included in letter A to C, part one, it's something that it's uncertainty and certainly. Should be discussed in combination with other issue we discussed yesterday, for example, the tax rate related illicit financial flows. And clearly this is something and including the exchange information that need to be discussed. In a context of a dedicated protocol and not certainly here. So to conclude, we strongly object to have this provision in the final convention. Thank you. Co-Lead · Khalid [2:00:39]: Indonesia, please. Thank you, Italy. Indonesia, please. Indonesia [2:00:44]: Thank you, Mr. Collett. Indonesia welcomes and generally supports the objective of this article, including the recognition of the added value of the explicitly addressing illicit financial flow within the convention. However, we also see the need to streamline this article, which we will submit our written comment letter. With respect to para one, concerning to the option of bracket and the issue of the view that formulation is foreseeable relevant is the more appropriate drafting. This formulation ensure that obligation to exchange information is based on a legitimate and objectively justifiable basis, rather than speculative and overly broad request. Thank you. Co-Lead · Khalid [2:01:32]: Czech Republic. Thank you, Czech Republic. Czechia [2:01:38]: Thank you, Mr. Cody, for giving me the floor. Czech Republic is fully devoted to the existing frameworks of the exchange of information, and we see the principle of foreseeable relevance as a cornerstone of the exchange of information in tax matters. Mr. Chair, I would like to echo the intervention of the distinguished delegate of Austria in its entirety. The article should be using a high-level language, and we would suggest deletion of this article and moving any discussion to the protocol. Also, we would like to thank you, Mr. Kolig, for explaining the reasoning behind including and not including certain texts into the draft based on the fact whether the proposal proposals represent majority views. We think that including views of significant group of member states, even though they do not represent the majority into the text, could also be helpful. This can be easily explained on the example of the reservations where during the inter-sessional meeting we have heard a significant group of members asking for the opportunity to provide reservations, but the draft in front of us does not allow any reservations to the framework convention. Hence, we would suggest, if possible, include into the text even views shared by a significant group of Member States, no matter whether they represent the majority or not, because this can help us better see what are all the possible readings and might aid us during line-by-line discussions that we would like to have in future discussions. Thank you. Co-Lead · Khalid [2:03:00]: Thank you. Noemi, please. Norway [2:03:06]: Thank you, Mr. Kohli. Norway has consistently argued that commitments should remain at high level as appropriate for a framework convention and not include provisions that are operationalized or self-executing. In this respect, we agree with the concerns put forward by many delegations, Austria, Netherlands, Germany, Italy, Czechia, others, and on the drafting of the provision as such and the reasons put forward in favour of deleting the article in its current form. And we suggest to replace it with a more high level worded provision. Alternatively, if going forward, this is kept in the draft, we think that here we also need a possibility to provide reservations, both because as drafted this does not comply with the current standard on EOI, which is very important to us. And also the list in paragraph one on the types of information to be exchanged, it doesn't really explain how and what information and a lot more infrastructure would be needed to actually carry out that kind of obligation. So we would be in favour of deleting this article. Co-Lead · Khalid [2:04:49]: Thank you. France [2:04:57]: Thank you. At the outset, I wish to thank you for that explanation. That allows us to better understand why this article is included in the text as submitted for this negotiation session. Having said that, we fully support what has been previously said by our European colleagues. In our view, this article is not appropriate for a framework convention because it is different in nature. It is not that we do not support the principle of exchanging tax information, we support the reference to that. within previous articles. Our point is that this text is operational in nature. It should be submitted or included in other instruments or protocols. What's more, deleting this text would allow us to avoid discussions on the precise parameters for the exchange of information, safeguards and other guarantees. These aren't points that enjoy consensus and avoiding at this stage those discussions when we don't need to have them right now gives us more time to study the other articles and more specifically those that have never been discussed. I thank you. Co-Lead · Khalid [2:06:11]: Thank you. No, I can go on please. United Kingdom of Great Britain and Northern Ireland [2:06:20]: Thank you. Mr. Koledin, apologies for my slight delay. It doesn't quite translate through the earpiece. So look, I think it's very good that I came just after my French colleague, as I think I have much of the same points to iterate as he did. I think when we read this article, I think we still have fundamental questions about the purpose. To us, this no longer seems like high level principles, but some way towards a commitment that would operationalize exchange of information. But for us, it, it's… seems challenging in the current form that it does that it seems neither to provide the legal gateway for it neither does it neither is it a statement of high level principles supporting exchange of information and transparency which we would of course support so I think in that constellation I think we would find it very helpful to have an explanation an explanatory note about what the intention of this article is to achieve I think that's something that we and other delegates have called for not just in this session but previously so again I think we would find that hugely It's very difficult for us to kind of understand the direction of travel on this without that. And then I think we would obviously second what other delegates have said regarding the appropriateness of an article that would be operationalizing. Exchange of information in a framework convention. Thank you very much. Co-Lead · Khalid [2:07:41]: Thank you. And maybe we have to ask the question we asked ourselves a while back when we did this. Are we saying that we should go back and put all the references into the clauses that they were in? Which means then we have to go back and look at all those clauses again. Because that's why we did this. Or we are saying that we don't want them, because I'm getting the inkling that we don't want it at all in this. Maybe that's a rhetorical question which we need to maybe ask ourselves as we go forward. We'll come back to this later. So UAE, please. United Arab Emirates [2:08:28]: Thank you, Khalid. We would like to also reiterate our points that we made during the fourth session. While we support the inclusion of an EOI article in the framework convention, the current text is overly detailed and prescriptive. Many operational elements would be better addressed in a future protocol, while the Convention should focus on high-level principles and commitments. We strongly support retaining established for CEB relevant standard, which is already embedded in existing international instruments and promotes consistency while avoiding duplication. Robust data. Protection and confidentiality safeguards are essential and should be clearly set out, including mechanisms for implementation, monitoring and enforcement. Finally, greater clarity is needed on the interaction between the Framework Convention, future protocols and existing international instruments to ensure coherence, avoid duplication and minimise unnecessary complexity and costs. In conclusion, we support effective exchange of information, but believe that the convention should remain principle-based, aligned with existing frameworks, and supported by strong confidentiality safeguards. Thank you, Khalid. Co-Lead · Khalid [2:09:47]: Thank you. Zambia, please. Zambia · Africa Group [2:09:52]: Thank you, Chair. I'm speaking on behalf of the Africa Group. Chair and fellow delegates, exchange of information is one of the key factors that are needed in enhancing international tax cooperation. And I think the reason why we are here in terms of the mandates, the UN framework convention is to see how we can enhance international tax cooperation, I think based on the TRS that we have. When we look at where we've come from in terms of negotiations, It's surprising that today we have other colleagues saying we should delete this article. Yes, it's possible people have reservations on how the article is structured or the detail that it has. But let's not forget that when we started negotiations, most of the articles had provisions where we had the paragraph relating to exchange information specific to that article. Then we had debate whether that was NEET or it was not NEET. And that's how we landed at having a specific exchange of information article. That notwithstanding, as we all know that we have already some standards, global standards on exchange information. Zambia is now a member of the Global Forum on Exchange of Information and other member states in here. But that doesn't entail then that we forget where we've come from in terms of why we have a specific article on exchange of information. There were articles, for instance, on illicit financial flows where indicated that we needed to have exchange information in that respect. And that's why you find in this article we have the issue of matching imports and exports. That was in that particular article. We had some elaborate provisions under the high net worth individuals, although we still have the general information there. So because of all that, it was agreed that we should have a specific exchange of information. So now when we say we propose to delete, are we saying we go backwards and start having specific text in each paragraph on exchange information? I don't think that would be the right way as the Africa group. So from the perspective of the Africa group, the texts as given by the college, it's acceptable in our regards. We have reservations on the concept of foreseeable relevance and we believe that this is an issue that can be elaborated in the protocols or other instruments and it's important from our perspective that the concept of foreseeable relevance is one that is very important in developing internationally recognized criteria. There will be need to develop a recognized criteria of what constitutes foreseeable relevance. Of such criteria in our view, we establish a fair balance between effective cooperation and legal certainty whilst avoiding overly stringent measures. and requests and therefore it's our view that whilst we agree that there should be foreseeable relevance concept it should not be in the commitments but it's something that can be dealt with in the protocol or in an instrument and therefore there will be needs to come up with a criterion probably through the COP. We also suggest that the current paragraph six of the call it text to be redrafted with some minor changes and to read In implementing this article, the state parties shall take into account the needs and capacities of developing countries and countries in special situations, as well as such guidance or instruments as may be provided from time to time through protocols or other instruments by the Conference of the States Parties. So the idea is to remove the word of limitations, but rather replace that with guidance that are other instruments that can be developed. through by the Conference of States Parties. I submit. Co-Lead · Khalid [2:14:25]: Thank you. Russian Federation, please. Russian Federation [2:14:30]: Mr. Co-Lead, distinguished colleagues, this has already been mentioned in statements by the Co-Lead, by the distinguished colleague of India as well. So we would merely wish to spotlight your attention on one aspect. In Nairobi, we discussed the commitments and every one of those commitments was like an effective, reliable means of exchanging information. So as not to repeat this in every article, there was a proposal and we discussed this together. the fact that it wouldn't be bad to have a separate line citing all of these commitments. The aim of that would be to point to a article on obligations. So to that end, such an article appeared and during the intersessional period we asked ourselves whether or not we needed a separate article or we could maintain in the into the obligations, the effective exchange of information, and we decided that it would be needed. So I just wanted to point out what was done here. So the aim was not to repeat every single obligation, including the exchange of information. So we think it shouldn't be deleted. We think it should be supported. We need to continue working on it. And on the whole, we support and agree with the position of our distinguished colleague from India. Thank you very much. Co-Lead · Khalid [2:16:18]: Thank you. Brazil, please. Brazil [2:16:24]: Thank you, colleague. I might warn you in advance that it might be a bit lengthy. Well, I like to reserve my right to change my mind. and adapt as these situations might change and details evolve. I have pretty much in line the same view as my Indian colleague. So There is no chance that Brazil will simply abandon the Global Forum or change the parameters that are in there or change the instruments because there are softwares developed, there are so much investment from all countries. I think that's not a feasible conclusion. Then the second question is then what do we do here? Well, number one, the Global Forum includes some jurisdictions that have their own international negotiation regulations on tax matters. So there are some jurisdictions there that are not part of the UN and vice versa. So there are some UN members that are not just jurisdictions. As I could see, there are basically 59 UN member states that are not listed under the MEAC Convention. Out of these 60, 59 to be more precise, 28 are African countries, 17 Asian countries, seven Latin American and Caribbean countries, six from the Pacific, one from Europe. So we do have a meaningful issue here, there's no doubt about it. On the other hand, we also have the concern, and it's a valid concern because it goes beyond the sphere of influence of ministries of finance and tax administrations, how to deal with taxpayer information. That is also involves an issue of a political issue under discussion of legislative bodies and parliaments and so on. And that's not an easy step to do. So countries, I have the impression that a lot of countries here will be, will have their hands tied if we go too far in the framework convention itself. If we establish in the framework convention a standalone article that would entail, would allow the exchange of information. It is true that by itself, not in protocols, in future protocols. It is also true that we had references before in the past on the exchange of information, different articles. Well, those references, they weren't -- I have the impression, as my memory goes, I have the impression that we did not have a standalone provision that in itself would allow the exchange of information. It was more a reminder that in order to fulfill the commitments, exchange of information would be necessary. And then the point would be that I had the impression that we would include in the protocols exchange of information as necessary for each protocol. So how can we make the connection here? So on the one hand, if we insist, I have the impression that if we insist to have a standalone article that would by itself allow the exchange of information, force countries to have the exchange of information even outside of the parameters of the global forum, a lot of countries would not be able or would have a strong argument to refrain from cooperating and signing to the convention. That's what I'm really afraid of. What should we do then? So I think that I would propose for us to be flexible here and have a general commitment here and then With that general commitment in the convention, the conference of the parties would be able to set recommendations, to set political manifestations that African countries should sign to the MEAC convention or do their own TIA agreements or whatever they find appropriate, or we could also have a future protocol just for the exchange of information. I think that for the moment, for the time being, That's what could bridge the positions. I do know that it's not what a significant number of countries don't want. I think that a lot of my colleagues will be unhappy with my position here, but I don't see how we can reconcile the views and bring together more countries without adopting a more open commitment here. Thank you. Co-Lead · Khalid [2:21:44]: Thank you. I think that we are not reading the article. I said I think we are not reading the article as it is. If we remember, and it's not Brazil, thank you. If we will cast our minds back, when we were talking about these things being in other articles, the issue was that there were supposed to be safeguards and other things which were not reflected in those articles. So if we look at this article carefully, realize that it's just the first clause that has brought all the things back in. The rest of it are all safeguards. So I think we need to also look at it. As we said, we are still looking at it. I mean, let's look at it. Let's see what the actual contents are as we go along. And I'm sure that as everybody said, as we've said from the beginning, none of these things are cast in stone. Ricardo just said that, I mean, we are allowed to change our minds. So it's not as if we are saying that it should be or it shouldn't be, it's up to member states to decide on that. All I'm doing is I'm giving the background as to why, how we got here. And so that as we continue to look at it, we know the background for it, that's about Rakha, do you want to come back? You're listening to us now. Okay, all right. So thank you, Razil. Saudi Arabia, please. Saudi Arabia [2:23:19]: Thank you, Mr. Khalid. Generally, we do not have an issue with having a designated article for EOI. With regard to paragraph two, and because information exchange is inherently reciprocal, it is essential that equivalent standards of data protection apply across the board and to guarantee see this shouldn't we ensure that confidentiality protection apply uniformly across the entire framework convention perhaps supported by structured governance mechanism such as states review process to ensure that strict standards for confidentiality data security and domestic law compliance are consistently met thank you. Co-Lead · Khalid [2:24:06]: Thank you Singapore please. Singapore [2:24:11]: Thank you, co-lead, and thank you for the revised draft. We share the sentiments of several speakers earlier, but we're nevertheless open to maintaining a standalone article on EOI. Our main concern is that paragraph one, the drafting language there creates self-executing obligations that are potentially very open-ended. And I think as members have mentioned earlier, without the ability to make reservations, it will be hard for participation to be rather broad. So perhaps some suggestions, and also keeping in mind that there is already current work done on exchange of information and standards have already been developed. Between maybe we should probably remove maybe, that's our recommendation, and keep the foreseeability relevant. and then consider dropping subparagraphs A to C. And after contributions to mention pursuant to applicable tax agreements, there are already many agreements out there that facilitate. The exchange of information. And if there is a need to bridge any gaps, these details could be elaborated upon in protocols and that would be appropriate place for us to discuss this. Thank you. Co-Lead · Khalid [2:25:36]: Thank you. Switzerland, please. Switzerland [2:25:40]: Many thanks, Mr. Koli. We were reading the article carefully, but in brief, I'm afraid we would have to align ourselves with the view expressed by many of the preceding speakers that the wording seems too detailed for a framework convention. If it is maintained at such an operational level, we must ask for the possibility to make reservations regarding such a provision for the reasons already explained in connection to Article 10. Many thanks. Co-Lead · Khalid [2:26:15]: Thank you, Switzerland. Israel, please. Israel [2:26:19]: Thank you, Chair. We think that Article 11 as is is very detailed. Like I said before, in Article 10, there are things that are not included. So it's on the one side too detailed and we think it does not fit a high level treaty. On the other hand, it's not detailed enough to be a standalone regulations. So we have a problem also we with paragraph two and like was said before, there should be international agreed rules regarding the data protection secrecy. And so we think that since we have reference to exchange of information in Article 10, we move to delete this article. Thank you. Co-Lead · Khalid [2:27:25]: Thank you, Belgium, please. Belgium [2:27:29]: Thank you, Mr. Koled. We, Belgium, is also still in favor of a framework convention with high level commitments because if you read Article 11 as it's now, stated, it is regulatory in nature. It sets out specific rules creating obligations, so it would fit perfectly under option one of the report of the Secretary General. It does not fit under option two, the choice that was made in the resolutions. approved by UN General Assembly. And then if we look also at the TOR, then exchange of information is mentioned as part of effective mutual administrative assistance in tax matters. And it also comes back that I agree because it says exchange of information for the implementation of the framework convention, but also that can just be mentioned on a high level without going too specific. and in the history it was mentioned everywhere with the relevant article, but that also can just be mentioned broadly without giving extra detail and make it obligatory because that is specifically mentioned also under option one that that should all the regulatory aspects. Should. Come in the protocol to the framework convention and specifically in the TOR there is the possibility mentioned to have protocol on exchange of information. So I do think if we want to be a bit consistent that we also have to bear all of this in mind and think why it is still also in brackets here in Article 11 means that there is also still a possibility to change this and this article is too detailed for a framework convention. Thank you. Co-Lead · Khalid [2:29:21]: Jafan please. Japan [2:29:25]: Thank you, colleague. I'll be really brief. We align with others that the current text specifies operational matters and is overly detailed. The language of framework convention should be kept at a high level to maintain consistency with other articles and the detail should be determined in the protocol if necessary. Thank you. Co-Lead · Khalid [2:29:51]: Thank you, Republic of Korea, please. Republic of Korea [2:29:55]: Thank you, Mr. Khalid, for giving me the floor. Korea recognizes the importance of effective exchange of information for international tax cooperation. Korea continues to believe that this convention should remain focused on high level principles, while detailed operational aspects of exchange of information are more appropriately addressed in the protocol, as mentioned by many delegations previously. We also believe that the Convention should maintain consistency with existing international standards in this regard. Korea supports retaining the foreseeably relevant standard as the governing standard for the scope of exchange of information. Thank you very much. Co-Lead · Khalid [2:30:49]: Thank you. Distinguished delegate of Ireland, followed by Nigeria. Ireland [2:30:55]: Thank you, Mr. Chair. We agree with the delegate for. Japan and many others as well that the wording here is too detailed for a framework convention. And if the article is stay in this format, we support the comments of. The distinguished delegate for Austria and many others to remove it. Thank you. Co-Lead · Khalid [2:31:14]: Thank you. Distinguished delegate of Nigeria. Nigeria [2:31:20]: Thank you, Chair, and good to see you. Welcome. All right, I think a lot has been said concerning this article. And Nigeria want to say and remind us that we have a number of commitments under this convention that requires exchange of information. In fact, information is critical to the work of a tax of revenue administration. Without it, you will not be able to effectively and efficiently discharge your obligations. So we require exchanging information amongst ourselves for us to be able to implement the provisions of the article regarding illicit financial flow, for example, taxation of high net worth individuals and so on and so forth. So how we do that, how we're able to achieve that becomes another issue. but that we need to exchange information. I think that is paramount and that is important. Should we therefore throw away this? I think Nigeria believe we shouldn't throw it away. You don't throw away the baby with the bath water. If you do that, I mean, it could lead to something that is so disastrous. We Therefore, I want to call that we take a critical look at this. If it is too worded or it is not as compact as expected, I think we could make it better. And for us as Nigeria, we have identified areas of improvement that we believe we can propose and people and delegates can look at. For example, if you look at paragraph one, I think the line, the third line was talking, is talking about taxes of every kind and description imposed on behalf of the state. And if you go to look at definition section, even though we have not defined definition, we have not been able to, we have not reviewed definition section. We are, the language used there is revenue of the government, I think something like that. So this phrase here doesn't mean the same thing, I think is part of what we need to look at. to ensure that we have something that an instrument that speaks to each other in a way that will make good meaning or the intended meaning. If we go to paragraph 1B2, the sentence says that transaction information to allow the margin of export and import of goods and services. But the objective of that, in other words, to facilitate detection and prevention of tax related illicit financial flow. So that is determining the purpose for which we are going to be using that information for. It has to be only detection and prevention of tax related illicit financial flow. So we believe that that phrase shouldn't come into it as long as the information is much export import it could be useful tax purposes and that takes me to the last aspect of it that I want to bring to the fore which is paragraph two paragraph two second to the last sentence here also is limiting um a kind of placing a kind of limitation which is saying that it shall be disclosed only to personal authorities. Concern with assessment or collection and enforcement or prosecution in respect of all the determination of our relation to the taxes referred to in paragraph one. So personal authorities shall use the information only for such purposes. We know that. The. jurisdiction that has given the such information could permit other uses so uh we we are of the opinion that we should not limit the usage of the information as long as the supplying jurisdiction has permitted such uses so these are some of the things that we are immediately able to spot and our proposal is just to allow delegates to further do a reflection on this And I must say that based on what the African group has also submitted, Nigeria adopts that. Thank you, Mr. Chairman. Co-Lead · Khalid [2:36:32]: Thank you. IBDT, please. Oh, sorry. Sorry, sorry, sorry. African Union, please. AU [2:36:45]: Thank you, co-lead, for giving us the floor. And we thank you for the manner in which you have been conducting this, uh, deliberations. The African Union aligns itself with the intervention delivered by Zambia on behalf of the Africa group, uh, and just now the intervention by Nigeria. The exchange of information is one of the key pillars, as we know, in international taxation and cooperation, and indeed a lot of work has been done in this area, but as has been acknowledged, it has not been fully inclusive, as is why we proposed this particular inclusion of an exchange of information article. It enables tax administrations to obtain the information necessary to administer and enforce their tax laws, combat tax evasion and avoidance, and address tax related IFFs, and of course, protect domestic tax bases. We therefore support the retention of this dedicated article on exchange of information. During the earlier stages of negotiations, as noted, exchange of information provisions appeared in multiple different individual articles and the decision to establish this particular article as a standalone provision was intended to provide a coherent and comprehensive framework applicable across the convention. Deleting this article would therefore create significant gaps or require exchange of information provisions to be reintroduced separately throughout the convention, which was the intention that we were trying to avoid here. In our view, this would fragment the framework and take the negotiations backward. A dedicated article provides greater clarity, consistency, and legal certainty. We therefore agree with the Africa Group and with other delegates that the article should be maintained, although we also agree that it is quite detailed for a framework convention and look forward to working with the Africa Group to submit a proposal that is more concise and relevant to what we are trying to achieve here through a particular framework convention. I submit, Chair. Co-Lead · Khalid [2:39:03]: Thank you. IDDT, please. IBDT [2:39:10]: Thank you, Mr. Coley. The Brazilian Institute of Tax Law. Supports the objective of Articles 10 and 11 to strengthen mutual administrative assistance and make international tax cooperation more inclusive and effective. In our view, the convention should build upon and expand the reach of existing instruments, particularly by enabling broader participation by countries that may not otherwise currently benefit from existing mechanisms. At the same time, inclusiveness requires an appropriate degree of flexibility, a rigid prohibition on reservations combined with an operative provision and exchange of information mechanisms in the framework convention itself may discourage participation by states with different legal systems, administrative capabilities and domestic safeguards. The proposed paragraph one draft of article 11 here is symptomatic of that concern. It may therefore be preferable for the convention to articulate the overall objectives and principles governing exchange of information while leaving operational details to future protocols on existing instruments. We do, however, welcome attention to baseline taxpayer safeguards, even in the framework context. While the framework convention should not become a tool to obstruct cooperation, it should also acknowledge that the preservation of due process and the prevention of abuse are worthwhile objectives. Exchange of information should be subject to a clear, foreseeable, relevant standard, effective safeguards against fishing expeditions, and appropriate rules concerning confidentiality, notification, and due process. Framework agreements on these safeguards and limitations are also important in fostering implementation and adherence. A balanced approach of this kind would facilitate broader participation and administrative cooperation. Thank you. Co-Lead · Khalid [2:40:55]: Thank you. ITAF, please. ATAF [2:41:00]: Thank you very much, Mr. Co-Lead. And once again, we thank you for the draft of Article 11. Mr. Kohli, the exchange of information is a vital and critical part of international tax cooperation and its inclusion in the framework convention is absolutely necessary. As we stated at the beginning of the week, we are looking at means and ways of ensuring administrability of the framework convention for our members. Having said that, our members are struggling to implement the current standards by the Global Forum. Many of our members are also in the Global Forum and ourselves as ATAF, we partner on several activities with the Global Forum. To date, we have no more than five countries implementing the CRS or automatic exchange of information standards because of its cost and consumption of resources. Ourselves as an organization, we're working on looking for ways of making that administrative burden more accessible to our members. Equally, Mr. Coleade, the current standards pose significant challenges for our members who are engaged in exchange of information but in some instances don't receive information given some of the technical issues that they face. And so we do propose that we keep this article. We align our comments with those delivered by Zambia on behalf of the Africa Group. And we further support the submission made by the Federal Republic of Nigeria in terms of how we could improve the current text and the language. As always, we commit ourselves to providing such improvements to text when the time comes. I thank you. Co-Lead · Khalid [2:43:11]: Thank you. ICRET, please. ICRICT [2:43:19]: Thank you, Mr. Chair. ICRICT welcomes the inclusion of Article 11 on the exchange of information in the COLIT draft. However, as it is currently written, it has a few problems. First, we support the inclusion of this article in the framework convention because we consider that this architecture is correct because the framework convention will serve as a framework for international cooperation. Moreover, an early negotiation of two protocol is taking place at the moment. The article on exchange of information will provide the necessary legal basis for exchange of information under the convention and its protocols. It would be impractical to create a new exchange of information mechanism for each protocol. So a solution needs to be created to address this problem at this moment. The framework must be operational from the outset to support these instruments. Second, the future Conference of Parties should have the mandate to deepen and elaborate on the details of the exchange framework as needed. Third, the text in Article 11 should allow for exchange of information from and with subnational level governments, not to limit its scope for exchange of information to be in practice allowed among countries with corporate income tax or personal income tax or even digital service taxes at different levels of government. Fourth, the exchange of information must be available for all taxes that fall within the convention's ambit and its protocols. We support the comments made by the Indian delegate in respect of aligning this article with other articles of this convention in consideration of the fact that this is a multilateral convention that is being negotiated and has also been highlighted by Zambia in the name of the African group that it includes specific commitments such as those on illicit financial flows. And I would add that it also includes commitments on high net worth individuals. And it will include, as I said before, a number of protocols, of which two are currently in negotiation. Thus, the bilateral framework from which most of the text has been taken from is not sufficient to support the exchange of information which will need to take place under this convention. In this respect, we also insist on the inclusion of a robust wider use clause, as has been also suggested by Nigeria and other delegates. The current draft does not foresee the use of exchange information for purposes other than tax, such as combating smuggling or other illicit financial flows. Without it, we will limit the convention's potential to tackle the full spectrum of illicit financial flows. As my colleague Alex Cofham from Tax Justice Network mentioned yesterday, there are cases in which a tax audit results in a parallel investigation on money laundering, customs violations, corruption, trafficking, and therefore interagency cooperation is key to address such crimes and the wider use of information is the key to allow such interagency cooperation in an international framework. Thank you. Co-Lead · Khalid [2:46:42]: Thank you. CEDD please. CEDEAO [2:46:47]: Thank you, Khalid. I speak for CEDEAO. Let me be practical. We have spent two days on this same debate. Keep the article or move it to protocols. Beyond the debate is one real question. How does every state stay comfortable? Here's the honest answer. Every state in this room stays in control. The convention states the principles, the protocol carry the machinery, and no state to join a protocol unless it chooses to. That is the whole system. Nobody is bound by surprise, nobody is bound by majority. Participation is always a sovereign choice. Now why does exchange of information belong in this text? Because every article we adopted this week depends on it. Wealthy individuals cannot be taxed on what no one can see. Illicit flows cannot be stopped by administration working blind. Assistance between states begin with information between states. No administration reaches beyond its border alone, not the largest, not the smallest. Exchange of information is how this convention becomes real. So deletion solves a problem that does not exist. and create one that does. Because of the protocol need a foundation to stand on. Our proposal is simple. Keep the principle in the text, choose the tested standard, send the detail to the protocol, and let each state decide on its own pace. The convention adds choices for every state. It removes choices from none. We stand ready to draft with all delegation. Thank you, Chairman. Co-Lead · Khalid [2:48:45]: Thank you for the interventions and they've all been taken duly taken note of. I believe that we'll be awaiting the written comments to enable us update the document appropriately. With that, we still have some time and I believe that we can move to Article 12 and begin If we're able to complete it, that's fine. If we can't, we'll continue tomorrow morning. So Article 12 basically talks about capacity building and technical assistance. And I believe that is something that is important to all of us. We have had some discussions in the sessional sessions. and is open now for comments and any other observations that we have. Thank you. Cheshire, please. Czechia [2:50:03]: Thank you, Mr. Chair. Thank you, Cheshire. You're very diligent in opening the discussions for us. Well, I don't want to keep you waiting. Thank you, Mr. Cody, for giving me the floor. Chequia supports capacity building to facilitate domestic resource mobilization. As regards Article 12, paragraph two, we would like to suggest adding the words and on voluntary basis after the words according to their capacity in the first sentence. In relation to paragraph four, we do not oppose this provision in principle, but we just would like to understand why it would make sense to have a permissible legal norm in the legal text because the text uses the word may, so we would like to understand it. Thank you very much. Co-Lead · Khalid [2:50:48]: Back to Chechia, please. Can you repeat the question? I wasn't too clear. Czechia [2:50:53]: Yes. In terms of paragraph. Yes, thank you. It's related to paragraph four. The text uses word may, state parties may conclude bilateral or multilateral agreements. So, and the question is, whether it makes sense to have what we would call in the Czech legal science permissible legal norm basically may allows you to do something. But our presumption is that state parties can do this no matter what. So if you use may, then we are just stating the state parties can do something that they can do no matter what is written in the in this provision. So we would like to understand why we chose this wording, whether we want to say something related to it. Thank you. Co-Lead · Khalid [2:51:45]: Okay, basically, if I remember, the suggestion from members was that aside or whatever is there, they should be allowed to also provide additional support to other states if there's a need for it. So that's basically why it's there. It gives the option for the MESTs to have bilateral arrangements to support each other. That's all. Belgium, please. Belgium [2:52:18]: Thank you, Mr. Koli. Belgium welcomes new wording and wants to thank you for the work done on this article. The Seville commitment recognizes the importance of scaling up support for DRM and strengthening capacity building efforts in developing countries. Belgium supports tax capacity building through several international organisations, including UNOPS Tax Inspectors Without Borders programme, which we believe is highly effective. Our tax administration has also actively scaled up its bilateral efforts in capacity building programmes with developing countries. We particularly value the demand-driven approach that responds to national priorities, capacities and development needs. In this regard, we welcome the less prescriptive wording compared to the previous version. The broad scope of the current article provides more flexibility, which is necessary, we believe, for capacity building and technical assistance to remain country-led and reflect the priorities and circumstances of the developing countries. We know from experience that duplication of efforts is a reality. We also know that certain needs for developing countries do not get met, be it because of lack of resources, expertise, or a combination. Therefore, Belgium attaches particular importance to the enhanced coordination in paragraph 2 strengthened coordination can improve the efficient use of resources and ensure that support is delivered in a complementary and effective way. In light of these considerations, Belgium supports this article and looks forward to working constructively towards its successful implementation. Co-Lead · Khalid [2:53:53]: Thank you. Norway, please. Norway [2:53:59]: Thank you, Mr. Kolaid. Cooperation on capacity building and technical assistance is a fundamental element of effective international tax cooperation, as also emphasized in the CRIA commitment. We therefore welcome the inclusion of this provision in the convention. Norway has long been a strong supporter of capacity building within tax systems. We have invested significant resources through our Tax for Development programme, which works to strengthen tax administrations, transparency and domestic resource mobilisation in partner countries through bilateral and multilateral channels, as well as through support to the civil society. Many of the activities listed in the article are in fact similar to the types of support already provided through these programmes. At the same time, we believe the article would be stronger if it were drafted in a more flexible and less prescriptive manner. Experience shows that capacity building needs differ significantly across countries and contexts. Effective support must be demand-driven, tailored to national priorities and able to evolve over time. For that reason, we are concerned that a detailed list of specific activities may unintentionally narrow the range of approaches that can be pursued, as well as prescribe specific activities in the context where they are not fit. So we therefore favor a concise provision that establishes a commitment to technical assistance and capacity building, while leaving sufficient flexibility for state parties and relevant institutions to determine the most appropriate forms of support. Furthermore, capacity building cooperation often depends on resources, expertise, national priorities and requests from implementing countries. It needs to be demand driven. For that reason, we would be interested in exploring whether more flexible formulations would be appropriate in this provision, including whether we should be assigning a role for the Conference of the Parties to identify, facilitate or promote relevant measures over time. And similarly to what asked, we are not convinced that paragraphs three and four add significant operational value to the article. Existing development cooperation and technical assistance arrangements can continue regardless of this convention. And states already possess the ability to conclude bilateral and multilateral arrangements on capacity building where they consider it useful and it is not necessary for the Convention to confirm that they may do that. It may appear even restrictive. We therefore suggest the streamlined version of this article, which includes a slightly altered version of paragraph 1 and 2 without the subletters and the consideration of the deletions of paragraph 3 and 4. Thanks. Co-Lead · Khalid [2:57:01]: Thank you. Brazil, please. Brazil [2:57:07]: Thank you, Kooli. I will repeat an idea or a concept that I have for a long time, and I think we have discussed to some extent in Nairobi. One of the -- I think the key commitments that is -- sorry, missing here is I think in the whole convention is there should be a commitment of the states to really take care of their own administrative capacity. So they have to commit to provide, to allocate resources, to build their own capacity in addition to the capacity building that will occur through cooperation. I have defended that idea several times and I think that it could be placed here in the first paragraph of this Article 12. Instead of making paragraph one relational or cooperative, I think we could say something, have a clear statement that each state party will have to build its administrative capacity and to allocate resources and so on. in order to fulfill the obligations under this convention. I think that is an idea that is missing here. We have repeated several examples, for instance, when it occurs some training or capacity building and the officials leave the department after they are qualified. And states should have that into consideration, that they should have plans so that they retain talents and so on. or allocate resources to buy software and so on. And I think that that is an idea that should be here because it has implications in the international cooperation. In the second paragraph, so I would amend the first paragraph in that direction to make it a commitment for states domestically. Number one and number two, in the second paragraph, we also support the idea of TTEC. to make it upon request or agreed. I think that idea has been repeated by other delegates as well. So it should read something as state parties shall according to their capacity and upon request of the beneficiary or something like that or other variations are possible. And the comment also on paragraph four that may conclude it, in legal drafting it's a bit misleading. We should work on improving the wording and the suggestion in paragraph four. Thank you. Co-Lead · Khalid [2:59:49]: Thank you. Sweden, please. Sweden [2:59:54]: Thank you for giving me the floor. Sweden has extensive experience of capacity building projects within the tax area, including peer-to-peer learning that has provided many lessons learned and shared experiences. We believe that capacity building is a very, very important part of international tax cooperation. We therefore welcome and support the inclusion of an article on capacity building and technical assistance in the framework convention. An essential part of this, which also aligns with Sweden's support within the broader aspect of financing for development and the integrated national financing framework, is that capacity building is demand-based and aligns with the national priorities of partner countries. We therefore believe that the article should, as Norway also mentioned, focus more on demand-based assistance. and that it should be possible to measure any improvements or outcomes. We do therefore hesitate a bit to include any examples to the article. We need to be able, through dialogue on the needs, specify this later on. Thank you. Co-Lead · Khalid [3:01:12]: Thank you. Singapore, please. Singapore [3:01:16]: Thank you, Colleen. Singapore recognizes that capacity building is indeed an important aspect of international tax cooperation, but we share similar views as Brazil, Belgium, Norway, and Sweden that capacity building should remain a demand-driven process so that limited resources can be channeled to. Where they are most needed. And according to the priorities of both partner jurisdictions, those receiving assistance and those providing assistance. So building on Brazil's suggestion earlier, we thought paragraph two could read instead, state parties may upon request and on mutually agreed terms provide one another technical assistance and so forth. We also had a suggestion that instead of the transfer of technology, because not very clear what that transfer is supposed to encompass, perhaps a sharing of technology and technical and legal expertise. Maybe more appropriate? Thank you. Co-Lead · Khalid [3:02:17]: Thank you. India, please. India [3:02:22]: Thank you. Thank you, Colleen. India welcomes the article on capacity building and technical assistance, and we reiterate our support to all such initiatives under the Framework Convention. India is part of several capacity building arrangements, and we will continue to engage, engaging in such arrangements as it is envisaged under this article. In this regard, we agree with the distinguished delegate from Norway that perhaps paragraph three and four venture into slightly more operational provisions. And maybe we can consider if these two paragraphs are really needed at this point of time and if they need to be retained. We also have a question on paragraph three, one phrase in paragraph three, which mentions drive accountability in the use of mobilized resources in paragraph two. So we wanted if some clarity could be given as to why this phrase has been included because for us, we think that this is a slightly more operational clause, which probably we would want to understand more in detail before agreeing to it. Thank you. Co-Lead · Khalid [3:03:37]: Thank you. Stakeholder one, please. IATP · GATJ [3:03:51]: Thank you, Mr. Chair, Mr. Kohli. I'm speaking on behalf of the Institute for Agriculture and Trade Policy and Global Civil Society coordinated by the Global Alliance for Tax Justice. From the onset, it needs to be clear that it is not only developing countries that need capacity building within the international tax system. We have indeed observed that both developed and developing countries have received significant capacity development in the implementation of the global minimum tax, for instance. We emphasize that capacity building must be needs driven, and for this reason, developing countries in particular must be involved in agenda setting and decision making. Consequently, we lament the removal of language related to agenda setting and decision making. Agenda setting and decision making help ensure that capacity building priorities reflect states needs, experiences, and evolving challenges. Without this element, there is a significant risk that the capacity building efforts of this article will be less effective. We therefore urge states to re-include participation in agenda setting and decision making as part of Article 12. An effective framework convention is dependent on the ability of states to implement it. This requires robust, coordinated, and sustained support. Technology transfer is one of the most critical forms of this cooperation. Arguably, it may in fact be the most important aspect of capacity support when compared to technical assistance. Currently, software licenses for tax administrations, just to do their job, can cost revenue authorities millions. Therefore, an approach to capacity building based on technology transfer and shared access could construct multilateral technological platforms as an alternative to a privatized data landscape, which helps obscure the true extent of tax evasion and avoidance. We welcome this provision within Article 12. Lastly, we reiterate that capacity building is not a replacement for system reform. States cannot capacity build their way out of a broken system, where even the most technically capable states lose billions in tax revenue every year. Indeed, we wonder why many of these states have not been more ambitious as they too would gain immensely from a clear, effective, and truly international tax system. The stated objective of this convention is to build an alternative to the current paradigm where nearly everyone loses and to define a multilateral tax system grounded in sustainable development. Capacity building in an equitably constructed tax system plays a crucial role. Thank you. Co-Lead · Khalid [3:06:28]: DM UN Foundation, please. DMUN Foundation · MGCY [3:06:33]: Thank you for the floor. I'm delivering this intervention on behalf of the financing for development constituency for the children and youth of the major group of children and youth on article 12. We welcome the recognition that implementing the convention will require sustained investment in infrastructure, human resources, institutional capacity, and technical expertise. Capacity building should be demand driven, nationally owned, and responsive to the needs, capacities, and priorities identified by each party. We particularly encourage meaningful opportunities for young tax professionals, researchers and public sector officials to participate in training, technical consultations, peer-to-peer learning and exchange programs. These programs should include practical placements, professional mentoring, regional cooperation and measures to retain expertise within national tax administrations. Building an intergenerational pipeline of technical expertise can strengthen institutional continuity and the long term sustainability of tax systems to strengthen the technical clarity of Article 12. We recommend several textual revisions in paragraph one, the phrase each state party shall cooperate to strengthen its capacity could be clarified by specifying the respective responsibilities of provider and recipient recipient states and confirming that cooperation should respond to nationally identified needs. In paragraph two, a member state should be replaced with states parties for consistency throughout the convention. Institutional mechanisms and exchange programs established under this subparagraph should also provide inclusive opportunities for early career officials and young tax professionals, taking into account equitable geographical representation and the differences in administrative capacity. We recommend that paragraph two include references to periodic capacity needs assessment, measurable national implementation plans, sustainable financing and evolution of long-term institutional outcomes. Technical assistance involving data analytics, information, information exchange or technology transfer should incorporate confidentiality, data protection, cybersecurity, maintenance, staff training and knowledge transfer requirements regarding paragraph two, where feasible, could be replaced with as appropriate and consistent with nationally identified priorities. This would preserve flexibility while establishing a clear expectation of coordination. The phrase boost impact should also be corrected to boost impact or replace maximize its impact. Coordination under paragraph 2e should include transparent consultation with relevant international and regional organizations, professional and academic institutions, civil society, youth representatives, and private sector technical experts where appropriate. Such participation should be based on clearly defined roles, disclosure of interests, and safeguards against conflicts of interest while preserving the authority and purities of recipient states. Finally, paragraphs three and four could clarify that assistance under the convention should complement rather than displace existing development and financial commitments. Bilateral and multilateral arrangements should specify financing responsibilities, implementation periods, monitoring procedures, expected outcomes, and accountability safeguards. The major group for children and youth supports capacity building that is adequately financed, measurable, secure, nationally owned, and designed to produce lasting institutional capability. Meaningful investments in the next generation of tax professionals will be essential to sustaining international tax cooperation over the long term. We thank you. Co-Lead · Khalid [3:10:09]: Thank you. China, please. China [3:10:12]: Thank you, Chair. We believe that capacity building and technical assistance are of great importance. Without adequate capacity, it would be difficult for states parties to implement this convention. At the same time, we have certain concerns regarding the treatment of technical assistance as a mandatory obligation, particularly due to the use of the word shell in the second paragraph. We agree with the points made by previous colleagues that technical assistance should be. Provided upon request. Thank you. Co-Lead · Khalid [3:10:54]: Thank you. ATAF please. ATAF [3:10:58]: Thank you, Chair, for giving us the floor. Chair, ATAF as an organization comprising of. 45 tax administration in the continent of Africa is well acquainted with the assignment in capacity building. And to that extent, we welcome the inclusion of article on capacity building in this very important multilateral instrument, which is the framework convention. While we appreciate the text as applied, we want to add a few comments. Number one, the current text does not cover the need to also include capacity to implement the protocols in the convention itself. And we think this is important, Chair, because it will eliminate the need to replicate capacity building provisions or articles and the various protocols as we have seen in some of the draft which is out there. That said, Chair, we also appreciate that in accordance with the terms of reference, paragraph, article two, paragraph two A has established or seeks to establish institutional framework for furthering capacity building. However, what we have not seen is the aspect of this text that supports that framework to mobilize resources on itself, by itself to support effort in capacity building. We are also a bit worried that there may be need to include in the text of the article an element which goes beyond just member states mobilizing on their own, but also not having the institutional framework actively support the efforts to build capacity. We also, Chairman, understand what Member States say when they say that capacity building must be demand driven, but we are of the view. That an article on capacity building must be broad and robust enough to cover both demand driven capacity building and other aspects which may not be demand driven. And this is important because this is framework convention. If tomorrow we realize that we require that other aspect and we have already shut the door. We may not have the flexibility to come back to amend the convention to include those other elements. We yield back, Mr. Chair. Co-Lead · Khalid [3:13:53]: Thank you. Kenya, please. Kenya · Africa Group [3:14:05]: Thank you, colleague. I submit this general comments on behalf of the Africa group and the detailed comments written input will follow. We support the adoption of this article, which will be critical in helping member states to develop capacity to administer taxes effectively. meet their obligations under the convention and its protocols and improve domestic resource mobilization. The article has provided for an extensive framework on institutional support, technology transfer, legislative strengthening, data analytics, tax education and training among others. We also note the special reference to developing countries in a number of the provisions under the measures listed in paragraph two are not exhaustive. However, we do have some concerns with the current drafting. one of which includes the scope of the draft. It is our view that capacity building and technical assistance should extend to the protocols while the current draft seems to refer to implementation mainly of the framework convention itself. The Africa group submitted written input in March and this will be resubmitted following this session with more detailed comments. Thank you. Co-Lead · Khalid [3:15:23]: Thank you. Morocco, please. Morocco [3:15:29]: Thank you very much for giving me the floor. I would like to support the comment made by Kenya on behalf of the African group. And besides, I would like also to add my voice to the observation made by the distinguished delegate from India about the phrase. to drive accountability in the use of mobilized resources. We think it's not clear enough. We're not sure what it entails. The way we understand it, we think it's beyond our role and mandate. But for that, we would like to seek clarification on this first. Thank you so much. Co-Lead · Khalid [3:16:13]: Germany, please. Germany [3:16:17]: Thank you, Mr. Koelie. We welcome the inclusion of a provision on capacity building in the Framework Convention as it constitutes a cornerstone of our common endeavor. We appreciate the work that has gone into drafting this provision, and we acknowledge the improvements made to the text. Germany strongly supports capacity development and technical assistance as key pillars of successful international tax cooperation and domestic resource mobilization more broadly. Supporting partner countries and their DRM efforts is the priority of Germany's development cooperation. This is reflected, among other things, in our comprehensive bilateral portfolio, our support for and cooperation with regional and international organizations, including the OECD, and Germany's hosting of the secretariat of the Addis Tax Initiative. Capacity development support should remain in our view demand driven, well coordinated and built on existing international and regional initiatives in order to maximize efficiency and avoid duplication. Financial and material assistance for capacity building should remain voluntary and subject to national politics. Any provisions on technical assistance should take account of the differing capacities of potential supporting states and should leave the type and scope of such assistance to their discretion. This does not diminish the crucial importance of capacity development for DRM, as emphasized, for example, in the Compromisso de Sevilla and the ATI Sevilla Declaration. Thank you. And thank you also for allowing me to speak past 6:00 p.m. Co-Lead · Khalid [3:18:02]: And with that, you've exhausted our five minutes that we had. And so we do have about two member states that means tomorrow morning we'll have to continue. So we could have finished by then. So thank you everybody. We'll close for today. We'll resume tomorrow morning. Have a good night.