(1st meeting) Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation - Fourth Session

Good morning, everyone.

Happy to see you all here in New York and happy New Year. It's a little bit late.

I declare open the fourth session of the Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation and call its first plenary meeting to order.

I will now deliver an opening statement.

Excellencies, distinguished delegates, dear colleagues, good morning and welcome to the fourth session of the Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation and its two early protocols. It's a pleasure to see you all here in New York as We open the first session of our work in 2026.

Over recent months, the intersectional work streams have continued with strong participation and genuine inclusivity among Member States. The documents prepared for this session reflects dedicated technical work and I commend all delegations for having sustained constructive engagement and keep the work moving forward through a particularly condensed intersectional period. This February session is important point in our process because it is where we move into text based work. Drafting cannot begin from blank page, nor can it proceed if we continue to treat every option as equally open. Therefore, we need to be practical.

We will need to identify workable elements and parameters and give our colleagues and Secretariat clear drafting direction while recognizing that nothing is being decided yet. To make that progress, we must manage time carefully. At this stage, we need to move beyond repeating established views and ensure our exchange is disciplined, constructive and text focused, with an emphasis on identifying concrete workable elements that can be taken forward. I encourage delegations to be as specific as possible, proposing language where feasible, flagging questions that can be resolved through drafting rather than extending debate and refining workable elements and parameters. This is what will allow drafting to move forward.

Between sessions, I will work with the piro, the Coolies and and the Secretariat to keep us on track while ensuring that all delegations have the opportunity to contribute meaningfully. Excellencies, during this session we have a specific work before us which is designed to advance us through this technical drafting phase. First, under the Framework Convention, the Committee will continue its technical review of the updated template draft, including new provisions on exchange of information and capacity building and technical assistance. This session is particularly important as decisions will delve into technical drafting, gather inputs from the Plenary and advance poll the Ticket and its structure, with a view to completing the drafting of all the provisions of the Convention and thereby preparing the ground for the addressing the outstanding issues in 2027. Second, the committee will turn to protocol one on the taxation of income derived from Cross Border services in an increasingly digitalized and Globalized Economy.

We will consider the options paper to be presented by the CO lead and engage in discussions to help clarify possible approaches and elements and parameters that will be needed to move into text based drafting.

These discussions are intended to narrow the range of options and guide the preparation of concrete draft provisions for the next session. Finally, the Committee will turn up will take up Protocol 2 on the prevention and resolution of tax disputes, beginning with the presentation of a CO Leads concept note on potential approaches and elements for the draft Protocol followed by discussions. Our deliberations will help shape the elements that will inform the next drafting phase with the aim of presenting a first draft of the Protocol during the fifth session. As noted in the Program of Work, that timing as between Protocol 1 and 2 may depend on the progress of our discussions excellences. As we proceed, let us maintain the spirit that has guided this process from the outset Inclusivity, mutual respect and genuine partnership.

Every Member State had the right and the opportunity to contribute fully on an equal footing and our discussions must remain open, balanced and efficient. We are committed to a process that is transparent and and anchored inequality in which no single country or group will dominate or steer our work. The engagement of stakeholders from international organizations, civil society, academia and the private sector also strengthens the quality and practicality of our discussions. Their perspectives help us to to ensure that the instruments we are shaping are not only technical reposit but also workable and responsive to real world challenges. I encourage stakeholders to continue to contribute constructively throughout this session.

Before we begin, I wish to express my appreciation to our colleagues for their leadership, to the Secretariat for their tireless support, and to delegations for your continued engagement. I also wish to note that on Wednesday, 4th of February, there will be no plenary meeting as we will hold informal consultation. This will also coincide with ECOSOC Special Meeting on Financial Integrity which will provide an important opportunity to reflect on issues related to strengthening global commercial coordination and policy and normal setting for exchange of information and data, including lessons learned from tax domains. With that, let us I would like first to give the floor to Mr. Navida Niff, Assistant Secretary General for Economic Development. The floor is yours.

Thank you, Mr. Chairman, distinguished delegates, ladies and Gentlemen, Representative Civil Society, It's a real pleasure to welcome you to the fourth session of the Intergovernmental Negotiating Committee for the United Nations Framework Convention on International Tax Cooperation.

Let me start by saying this clearly.

Getting to this point has taken an extraordinary effort and I want to acknowledge the outstanding leadership by the CO Chair, members of the Bureau and the CO leads.

The documents before you reflect long hours of technical and legal work. They reflect close cooperation across delegations. And for many of you, they reflect work done over the holiday period. That commitment matters. It speaks to the seriousness with which Member States are engaging in this process.

Allow me to highlight three issues as we begin today. First, where we are in the process. We are entering a crucial phase.

From the start, this negotiation was designed to move in stages. 2025 was about scoping, about defining the building blocks. 2026 is about drafting, and 2027 is where the final political decisions will be taken. This session marks the pivot from scoping to drafting.

We are on schedule and we are moving toward the next major milestone, the preparation of the zero draft this year. What happens in this room over the next two weeks will shape that outcome. We count on your continued energy, commitment and engagement. Second, the opportunity before us. This Convention is not simply about filling gaps in the existing system.

It is an historic opportunity. For the first time, we have the chance to build a truly universal framework for international tax cooperation, one that reflects the realities of today's global economy. If you get this right, the impact will be real and big.

It can help curb illicit financial flows. It can help ensure that multinational enterprises pay taxes where economic activity actually takes place. And it can strengthen domestic revenues where even modest gains can translate to into major development impact.

Our task is to create a framework that is fit for the 21st century, a framework shaped by the shared priorities of all Member states. Third, and finally, multilateralism that must guide us. International tax cooperation goes to the heart of national sovereignty. It affects our states finance development, and it touches directly on sensitive policy choices.

That is precisely why this process matters. It must reflect the United nations distinctive approach to multilateralism. Open, inclusive, transparent and grounded in mutual respect. The legitimacy of this Convention will depend not only on what we agree, but on how we arrive there. With that, I will now hand over to the Chair, who will guide us through the organizational work and the issues before us in the days ahead.

And thank you for your engagement, for your presence and for your leadership. Thank you, Chair. And let me assure you, DASA is here and our team to lend its full support to this process. Thank you, Chair.

I thank the Assistant Secretary General.

The Committee will resume its consideration of Agenda Item 1, entitled Election of Officers. In accordance with a General Assembly Resolution 79235 of 24December 2024, the Committee shall elect 18 Vice Chairs and a reporter. Elected on the basis of equality, geographical representation and taking into account general balance One of the positions of Vice Chair from among the Western European and others group has remained vacant. I have received the nomination of Ms. Sarah Gru of Denmark for the position of Vice Chair. May I take it that the Committee wishes to elect the nominee by acclamation as a Vice Chair of the Committee?

I hear no objection. It is so decided.

On behalf of the Committee, I congratulate the Vice Chair. The Committee has thus concluded this stage of its consideration of Agenda Item 1. The Committee will resume its consideration of Agenda Item 3, entitled Organizational Matters. Members were recalled that by its decision to take an answer February 2025, the committee adopted the program of work of its SE on the understanding that it might be revised during the sessions as needed. In this connection, the revised program of work is contained in document CRB24, which has been distributed to delegations via Edelegate and is available on the website.

Members will also recall that by its decision3 taken on 6 February 2025, the Committee decided to take decisions at the beginning of each of its sessions on any new applications by international organizations and on participation of representatives of other relevant non governmental organizations, civil society organizations, academia institutions, the private sector and other stakeholders. In this connection, the Committee has before a draft decision CRB 23 entitled Participation of international organizations, Civil Society and other relevant stakeholders and draft amendments CRB 25 and CRB 29.

I now give the floor to the representative of Belgium to introduce draft amendments CRB 25.

Thank you, Mr. Chair. Distinguished delegates. On 7 January 2026, the Secretariat shared a revised list of multi stakeholders applying to participate in this fourth session of the Intergovernmental Negotiation Committee. These multi stakeholders include, according to a AC298, three relevant non governmental organizations, civil society organizations, academic institutions, the private sector and other relevant stakeholders.

As it appears, objections were raised during the non objection procedure in relation to two Non Governmental Organizations and two Ad hoc Parliamentary Groups. In the draft decision of 14.01.2026 contained in a AC 298 CRP 23, these stakeholders are no longer listed among those proposed for admission. On the basis of the available documentation, it is not evident whether and if so, how the respective objections were substantiated, nor is it apparent by whom those objections were raised. At the same time, the documentation from the Secretariat confirms that valid applications were received from the stakeholders in question. Against this background, the reasons for their exclusion remain unclear.

Belgium is firmly committed to ensuring the inclusivity and the transparency of the work of the inc. We therefore strongly support inclusive and meaningful engagement by multi stakeholders whose contributions are essential to building effective and legitimate international tax corporation. Guided by these considerations, Belgium has submitted an amendment, CRP 25, which advocates for extending the list of admitted stakeholders to include the stakeholders concerned. The amendment submitted by Belgium serves this very objective. We invite all delegations that share the principles of inclusivity and transparency to co sponsor CRP2 and to support its adoption by the committee. Mr.

Chair, building on these considerations and in light of the broader discussion on stakeholder participation, Belgium also wishes to briefly comment on CRP 29. As colleagues will recall, the stakeholders concerned were assessed by the Secretariat as having submitted valid applications and were included in the initial proposed list of stakeholders. Stakeholders as already mentioned, no convincing information has been provided to demonstrate that they fail to meet the agreed criteria, nor have the grounds or authors of the objections been made transparent. From our perspective, removing only the Parliamentary groups would introduce an arbitrary distinction between stakeholders who have all passed the same technical eligibility assessment. It would weaken one of the strengths of this process, its broad inclusivity and complete transparency.

In sum, Belgium believes that CRP 29 would undermine the inclusivity, transparency and credibility of the Inc's work. We therefore respectfully request that a Committee proceed to a vote on CRP 29 and we will vote against it. We encourage other delegations that share our principled position on meaningful multi stakeholder participation in this process to do the same. Thank you.

I thank the representative of Belgium. I now give the floor to the representative of Russian Federation to introduce draft amendment CRB 29.

Esteemed Chairman Dear colleagues, the Russian Federation is making an amendment to Belgium's proposed amendment to the decision on the accreditation of observers to the Committee. This amendment aims to remove from the list of accredited observers ad hoc groups of parliamentarians. Members of Parliament are representatives of the state authorities, namely the legislative branch. Negotiations within our Committee are conducted by States via the Executive Branch which bears international legal responsibility for the development and subsequent implementation of agreements. The ad hoc groups of parliamentarians mentioned in our amendment are not legally formed organisations.

They do not have a precisely determined mandate, nor do they have formalised membership, representative structure or accountability mechanisms. As we understand it, these sorts of groups do not meet the minimum criteria applied in the UN's practice to non governmental organizations and other stakeholders that wish to participate in the intergovernmental process. As observers, we also believe it important to avoid setting a precedent in which various different political groups from the same Parliament could try to get separate accreditation to the Committee that would inevitably lead lead to domestic political and inter party debates being moved into the international arena and would complicate the negotiating process. At the same time, we're not denying the possible utility of the participation of members of Parliament in the work of the Committee. That participation, where necessary, should be done within the composition of national delegations and should be coordinated by the relevant governments.

Lastly, we consistently oppose the erosion of the intergovernmental nature of the UN by by undermining the no objection procedure when considering applications for accreditation that is provided for in a decision of the Committee. Given the aforementioned, the Russian Federation does not believe it possible to give groups of parliamentarians observer status in this Committee. Thank you for your attention.

I thank the representative of Russian Federation. I now give the floor to the sket.

Thank you, Chair. I'll address co sponsorship of draft amendment CRP25 and CRP29 in turn. First, CRP25, if any country is not listed on CRP25 wish to co sponsor CRP25, please press the microphone button.

Now I see. Czechia, Sweden, Switzerland, Ireland, Germany, France, Portugal, Finland, Slovenia, Bulgaria, Italy, Malta, Poland, Spain, Cyprus, Latvia, Norway, Kingdom of the Netherlands, Austria, Liechtenstein, Lithuania, Slovakia, Luxembourg, Greece.

And on CRP 29, if any countries not listed on CRP 29 wish to co sponsor CRP 29, please press the microphone button. Now.

I see none. Thank you, chair.

Distinctly good of Romania. Please go ahead sponsor the. Okay. Thank you.

Okay. It has been noted the first one.

CRB 5. Yes. In line with the other colleagues from here.

Okay. Your sponsorship is considered. Thank you.

I think. This is Katriet. We will now proceed to consider draft decision CRB 23 and draft amendment CRB 25 and CRB 29 before we take action on draft decision. In accordance with Rule 130 of Rules of Procedures, the Committee shall first take a decision on draft amendment CRB 29 followed by draft amendment CRB 25.

As recorded vote has been requested. We shall now begin the voting process. Those in favor of draft amendment CRB 29, please signify. Those against abstentions. The Committee is now voting on draft amendment CRP 29 submitted by the Russian Federation.

Will all delegations confirm that their votes are accurately reflected on the screen?

The voting has been completed. Please lock the machine.

The result of the vote is as follows. 1 in favor, 1 against 39. Abstention 22. Draft amendment CRB 29 is now is not adopted.

May I take it that the committee wish to adopt draft amendment 25 crb 25?

I hear no objection. It is so decided.

So the representative of Turkey. The floor is yours.

Thank you, Chair. Turkey is a strong supporter of inclusive and constructive multilateralism. In this context, we attach importance to the meaningful participation of NGOs, civil society organizations, academic institutions and the private sector in the work of the United Nations.

In line with the principles and purposes of the UN charter, Turkey supports NGOs whose work genuinely contributes to the constructive progress of the Committee's mandate and to the promotion of a fair, inclusive and an effective international framework for.

I'm sorry for interruption, but we have another opportunity later coming to explain you your vote. Okay, so if you have a point of order right now.

No, no, I'm just.

Okay, so we will come to.

Yeah, we will come to the expression.

May I take it that the Committee wish to adopt a draft decision CRB 23, as amended?

I hear no objection. It's so decided.

Delegations wishing to make a statement in explanation of vote after the vote on any of, in any or all of the proposals, including the draft decision and the draft amendments are invited to do so now in one intervention. I remind delegations that the statement in explanation of vote are limited to five minutes.

Distinguished representative of Turkey.

Thank you, Chair. I would like to make a statement on explanation of vote for CRP25. Turkey is a strong supporter of inclusive and constructive multilateralism. In this context, we attach importance to the meaningful participation of NGOs, civil society organizations, academic institutions and the private sector in the work of the United Nations.

In line with the principles and proposals of the UN charter, Turkey supports NGOs for whose work genuinely contributes to the constructive progress of the Committee's mandate and to the promotion of a fair, inclusive and effective international framework for tax cooperation. On the other hand, we do not support NGOs that engage in activities running counter to the purposes and principles of the UN Charter or that undertake politically motivated actions against certain Member States. The amendment adopted today unfortunately allows valid objections to be overridden without adequate understanding or security of the activities of the NGOs concerned, thereby transforming this matter into a politically potentially politicized one. In fact, the proponents of the adapted amendment do not appear to have detailed information regarding the objectives, activities and sources of financing of the NGOs to which objections has been raised by certain Member States. Furthermore, no proper justification had been provided as to the grounds of which all of the objected NGOs and stakeholders would be critical to the word of the INC process.

For the sake of transparency and to ensure informed decisions decision making, we would have preferred to receive detailed information in advance on how these NGOs and stakeholders intend to contribute meaningfully to the work of the inc. Looking ahead, our modalities should be designed in such a way that all Member States are properly informed in advance of the intentions of the NGOs wishing to participate in such technical meetings, as well as how they plan to contribute to the technical work at hand. This violation of non objection principle has the potential to transform a technical and inclusive process into a politically charged one and may deter constructive engagement. We therefore call for transparency and respect for concerns of all Member States when determining NGO participation and reiterate our support for the application of either the criteria set out in the ECOSOC Resolution 1996 slide 31 or the non objection principle as appropriate. Safeguards.

Turkey remains committed to safeguard to supporting the work of this Committee and will continue to contribute constructively to the fulfillment of the mandate. Thank you very much.

Thank you. I see no more requests for the floor. So the Committee has just concluded this stage of its consideration of agenda item three before during the meeting.

I would like to advise that immediately after this meeting the Committee will hold an informal meeting. Thank you. The meeting is adjourned.

So now we close the formal mood meeting and now we're going to move to the informal mood to start our discussions and Work Stream 1 is a framework Convention. So I will ask everyone just to keep seated. We will take like just 3 minutes to reorder the podium and we will start immediately. Thank you.

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Hello. May I ask everyone to have a seat? We will start now. Please back to your places. We're going to start now.

Hello everyone. Now we are starting our informal meeting in which we are going to discuss for this week the the work that had been done for Work Stream 1, which is the Framework Convention. Just I will give a little bit of background to remind everyone that we started in August session by having the issue notes and following the issue notes, we start the drafting process for the convention. We presented the first text, partial text for the convention in Nairobi. After Nairobi, we digested what we heard in the plenary session in addition to all the intersectional work with Work Stream one from many countries used to participate in all the meetings.

And we reflected this in revised text in addition to a new text by introducing two new articles which is exchange on the one on the exchange information, second one on the capacity building. And in doing so we all the time just keep considering the logic order of the article in which we are developing and the dependency between the different articles just to make sure that we are proceeding with, with enough or sufficient speed to meet our deadline and on the same time considering that the integration and order of the articles, the logical order of it. So I will start with saying thanks to our colleague Daniel, who is doing a great job in Work Stream 1, and of course to the Secretariat. And now I'm going to hand over to our colleague Daniel to take you through a presentation. Then after that, discussions on different articles.

Thank you, Daniel. Floor is yours.

Thank you, Chair, and welcome to everyone for this session. And Happy New Year to those of you we haven't met already.

We really appreciate the contribution that Member States have made both in oral and written submissions and during the intersectional sessions. It's been great hearing all the different views and a lot of work putting them together. But I believe we have made some progress now during the second and third sessions, as Chair just mentioned, we had quite a number of inputs which we've put together to enable us come out with a national document for us to discuss. And while we are on it, we also wish to indicate that because it's a discussion stage, there's quite a number of rolling discussions going on where there are issues that will come to over and over again before really come to some final conclusions when we are sharing the text. And so what's been happening, if some have noticed, is that there are some of the texts that come in and then go out again.

There are some articles we started work on, but then in the coming. The discussion paper we are working on right now will not see those articles. It's not because they've been abandoned. But then there's some additional work that needs to come before we can have further discussion discussions.

So in the preceding sessions, one of the issues that is still outstanding is the level of the various commitments and how high level or what really we should be looking, how broad they should be is something which we'll need to clarify at some point in time and I'm sure in due course we'll get that done. The other thing we need to know is that there we've introduced some new articles that are closely related, that are closely related to the commitments which we also discussing. And so we have a few slides, some slides that we are putting up. There are two slides I'll put up that look at the sliding nature of what we are doing and how we expect to go ahead.

Just technology issue. We will have the slides now. Yeah. So slide three. Go to slide three.

Yep. So.

So what we'll notice as we go on and with the template that we Share Shared we realized that there's no text or nothing in the template on dispute resolution issue prevention and resolution as we call. There are several issues that have cropped up based at the second session and then the third session which require that we have some further discussions on the relationship between the three mentions of dispute resolution in the Framework Convention. One, as a commitment, two as a protocol and third as the structural elements where we are talking about disrespect mechanisms. So we've had to take a seat back and look at all the suggestions we received and then be able to come out with some drafts we can consider. So we realize that the discussion we are going to have now will not have this resolution in it.

Next slide, please.

So basically we've sort of done a little more. A few more changes. In addition, we've updated the order in which we are addressing the issues and with that the provisions that were to be addressed early. We realized that that unfair allocation we revised a bit. The one on sustainable development remains unchanged, though there's been some discussions on it.

High net worth individuals have been revised. Mutual administrative standards have been revised. There's been a revision on legislative financial flows, Harmful task practices have been revised. And then we've introduced a new provision on capacity building and technical assistance now on those provisions whose drafting depended on at least part on the drafting of commitments. Definitions We've started looking at some tentative definitions, but we haven't gone to a point where we can really.

We send some indicative ones out during the work sessions, but we haven't really done anything in depth that brings out something for us to discuss. But they were indicative and to allow us to just think through the definitions. Conference of Parties we've moved from the third column into the second column. And because there are certain dependencies that we need to look at. Financial resources.

Data collection analysis still remain the same. We've had initial look at data collection analysis. We are yet to put anything together. We have exchange of information which is new and we'll come to that in a minute. Because of the changes that Members requested, effective prevention and resil task issues.

I just mentioned that we are trying to resolve some scope issues, so we'll come back to it later. Re and verification in subsidiary bodies.

The Secretariat has been moved into this from the second to the third column. Amendments to the commence relationship with protocols remain unchanged and then other formal matters. So we are still maintaining the order in which we said we'll have the discussions with barring these few changes that we've made.

So with that I think I believe that. Okay, let's go to the next slide since those ones were just procedural.

Now, on sustainable development, which we'll look at in a minute, the text has not changed, though there has been some suggestions for additions to the text that we have. But then this has not really been concluded. And so we still have the old text that we are discussing. We haven't changed anything there yet. And so.

And maybe we can put up the text for. Text is up. Yeah, so the text there hasn't changed from Nairobi. It's the same text. So open up if members have any.

Any comments on that before we continue.

One minute, please.

Okay, well, I think we can at least text. So Austria, please.

Hi, good morning everyone. Good to be back in the room. Thanks for hosting this new session. Just a quick question on the slide with the blocks and with the order of. When we going to discuss the different topics of the Framework Convention?

I'm not sure if I just did not see it, but I think one of the most important topics that we have identified as needing to be discussed at some point is the interaction with other instruments. And. And it's the Article 15 now in the draft skeleton. So it was not in any of the boxes. So I was wondering what the suggestion would be when we will discuss it.

Thank you.

Okay, as we mentioned, if you look at. It is in the second box which looks at the commitments as in the second, which look. Which depends on the commitment. So basically after we finish the commitments, that's when we'll have that discussion.

Okay. Jamaica, please.

Thank you, Chair. And I'm greeting everyone here. Well, for the New Year.

Well, my only comment is that we seem to be making some progress from the bare minimum statement that is currently the text, which of course Jamaica had indicated that we did not find to be of much substance. We're not completely satisfied that this addresses our main concern. That of course being the issue of environmental issues. Nevertheless, we are heartened that the language seems. Seems to be moving in a direction that is workable.

Thank you.

Thank you. Jamaica, Brazil, please.

Thank you, Chair. Good morning to all.

So, about this sustainable development article. We would like to welcome the replacement of it and to the beginning on the commitments. And we would like to reaffirm our willingness to expand the current language. We consider the current version of the article to be very limited as it only states that international tax cooperation will contribute to sustainable development in its three dimensions in a balanced and integrated manner. We would like to make the commitment more concrete and for that we should identify the ways through which international tax cooperation can contribute to sustainable development.

The Brazilian delegation would like to suggest the inclusion of reference to the mobilization of domestic resources, progressive taxation and the importance of addressing historical and structural inequalities that permeate fiscal systems. Reference to these terms reinforce the objective of shaping a more inclusive and development oriented international tax architecture. According to the terms of reference, one of the objectives of the Convention is to establish an inclusive, fair, transparent, efficient, equitable and effective international tax system for sustainable development while addressing challenges to strengthening domestic resource mobilization. We would like to support, with some modifications, the modifications mentioned above, the language proposed by the United Kingdom that seeks to elaborate on the relationship between international tax corporation and sustainable development, referring to the promotion of human rights, environmental sustainability and the integration of tax and sustainable development objectives. Another positive aspect of the British proposal is the suggestion that the Conference of the Parties conduct periodic reviews of the Framework Convention's contribution to the three dimensions of sustainable development in consultation with other international forums.

Thank you.

Right, thank you, Razil, Sweden Please thank you Chair for giving the floor and also Good morning colleagues. Thanks also to the colleagues for presenting the new drafts. Much appreciated. We have a few comments and questions regarding this article. First, we appreciate that this article has been moved earlier in the text, an adjustment that was advocated for during the previous sessions, and we wish to express our strong support for addressing this important aspect in this Draft Framework Convention.

However, we also see scope for further strengthen the language. For example, we would welcome an explicit reference at the end of the article to the need to respect and protect human rights as well as to promote gender equality, both of which are essential and mutually reinforcing elements of achieving sustainable development. We also support several of the suggestions made by the United Kingdom during the work stream meeting, in particular the aforementioned reference to human rights, but also the addition of jurisdictions. We also support the polluter pace principle as such. However, we would advise caution regarding the formulation of any proposed monitoring mechanisms.

This is just to avoid establishing new or new for us, given the existing frameworks such as the vnr, the Voluntary National Reviews for Sustainable Development or the UPR for Human Rights. We also reiterate our request for clarification on the rationale behind adding the phrase taking into account different capacities in this article, we would much appreciate further explanation on how this commitment is intended to be implemented in light of that addition. And lastly, I just wanted to also add that we have a similar question on the timeline as was mentioned from the delegation of Austria. It would also be helpful to understand already now when the draft article on reservation would be presented So I just wanted to mention that already now. Thank you.

Spain, please.

Thank you, Chair. Spain welcomes the inclusion of an article on sustainable development in the Framework Convention. We also support the wording of the article, which is in line with what appeared in the Terms of reference, and we support subsequent development, but always as part of a protocol. In general, we support the fact that the Framework Convention would include high level commitments that would subsequently be developed in the corresponding protocols. We are also concerned, as my colleague from Austria and from Sweden said about when we come to Article 15, we believe that that should be discussed as a priority because the way that that article is drafted determines how far or less far we may go with our commitments.

We think that that is an article which needs to be discussed almost. First of all, thank you.

Thank. Thank you. Spin. I didn't see any member states requesting for ops.

Denmark. Okay, seems all right. So Denmark, please. Thank you, Khalid, for giving me the floor and thank you everyone for the election. I'm very happy to be here and I thank you for all the work that have been put into this work stream.

In regards to sustainable development, we want to echo the feeling in the room that it's very positive to have such an article in the text. And we, as Brazil and Sweden has said, also favor the UK proposal of flushing it more out. So that's my initial remarks. Thank you.

Right, thank you. Denmark, France, please.

Thank you, Mr. Chair.

My thanks to all of the colleagues for the work that has been done in the context of the work since the Nairobi session. For our part, we would support and echo the position that has just been outlined by Spain with support for this article and its importance. First of all, from our point of view, this article also from a technical standpoint, corresponds to a Framework Convention with an article that has a general scope, which then needs to be operationalized by the Protocols. And we think that it's in that context that we should work further. But for a Framework Convention, the level of this article and the commitment that it represents seems appropriate for us.

And lastly, also to echo what was said by several of my colleagues before me, we think that it's important that as quickly as possible we discuss Article 15, because the link between the commitments and other instruments will allow us to specifically define what we're going to put in those commitments. Thank you.

Thank you. France. Can we have China, please?

Thank you. Though there is no separate part of general statement, I still would like to make some general comments on the work of Work Stream one at the beginning.

First, I'd like to express our Appreciation to the CO lead and the Secretary for their efficient work in providing the latest updated draft on January 22nd. We think this draft has positively incorporated many of valuable and widely accepted comments and suggestions put forward by State Parties during the online meetings in January for which we are very grateful. With respect to of the Article 4. We believe this article is very important as it captures the shared commitment to promote sustainable development through international tax cooperation. We support the current wording the text which is appropriately high level and consistent with our vision for the framework.

We do not support very much with adding other issues like human rights to this article because we think it is not of high relevance to taxation. Thank you.

Thank you. China, Norway please.

Norway please. Please give the.

Thank you Mr. Kohlid and hello to everyone. It's a pleasure to be back here. We would also like to thank you and the Secretariat for the hard work in the very short time between Nairobi and this session. So thank you for that. As a general remark, we would agree with those delegates that has pointed out that there are important linkages between the commitments and other parts of the Convention and we believe that there is.

It's very important to discuss the commitments in close relation to, amongst others, the provisions on interlinkages with other agreements and also the Conference of the Parties coming to Article 4.

Sustainable development, human rights and gender equality are fundamental priorities generally across the work of the UN and it also has a place in our work. It's important that international tax cooperation takes place in a way that supports broader development outcomes and therefore Norway has also previously made the point that sustainable development should be a cross cutting issue in this Convention. And we appreciate the relocation of this article to the beginning of the Convention. We appreciate the intention and work behind this article as well as the constructive proposals that have been put forward during our discussions on this and in in written input. So we support continued reflection on how international tag cooperation can contribute positively to sustainable development in a manner that is practical, proportionate and consistent with the mandate of the Convention.

Thank you.

Thank you. Norway, Mexico, please.

Thank you very much. Golid and hello to everyone. Similar to other colleagues as the room, we're very pleased to see the inclusion of Article 4 on sustainable development. I think that throughout this negotiation we've highlighted the impact and linkage of tax in the further development of sustainable projects for countries. So we would like to thank the colleagues and the Bureau for drafting this language.

Similar to others, we do think that we can further strengthen it and maybe enhance it with linkages to other issues related to the impact of tax on sustainable development. I know that the colleague from Brazil mentioned some of those issues that are the ones that are also contained in the UN resolution on international tax cooperation. And from this which convention was set out to be drafted. So we would be happy to look into that maybe as well. Just to mention, I know that the conversation here between the linkage of sustainable development with human rights has been long standing.

As you may recall, Mexico, during the terms of reference negotiations, we advocated for human rights to be a principle of the convention, overarching the protocols. We know that that's not the conversation we're having this time, but we do see merit in maybe having a conversation surrounding whether or not this article could link to that important interlinkage for the benefit of the overall convention and its protocol. So happy to work on those things and once again, thank you for the work and looking forward to see where this goes in this session. Thank you.

Thank you, Mexico, the Kingdom of the Netherlands.

Thank you, Koleed. And I also would like to express my appreciation for showing this new draft of some provisions for the Framework Convention. We are also very supportive of the inclusion of this article in the Framework Convention. And we agree with Spain and France and others who have argued before us that this article is drafted in a high level manner which is sufficient for this Framework Convention and is very suitable. However, we also share some questions raised by Sweden with regards to the first part of the sentence, which has taken into account different capacities, as this does not correspond to the text of the terms of reference.

So we would also like some explanation to the meaning of this first part of the sentence. And we would also like to express some sympathy towards colleagues who have raised the issue of including a reference to human rights in the text of the article. We would also support that while keeping the balance of keeping this article high level. Thank you very much.

Thank you. Netherlands, Ghana, please.

Thank you very much. Chair and I take this opportunity to thank you very much and the Secretariat for putting together this draft and for such a diligent job between now between when we had Nairobi and this time. So I thank you very much for the draft regarding this specific article. I just wanted to indicate first and foremost that I'm speaking on behalf of the Africa Group and I'd wish to make the following statement. First and foremost, the Africa Group supports the paragraph as it was drafted in the terms of reference.

We felt at that time that the paragraph was sufficient enough to broadly reflect the linkages between sustainable development and international task cooperation. And also it was broad and high level in that it didn't go into the specific details. So broadly speaking, we can go along with the paragraph as it was originally drafted. Regarding this current version, we'd want to and the proposals we have had on the floor, we'd want to indicate that the AFCA group would not be able to go along with expanding this paragraph, expanding it to include other issues having to do with human rights and other elements. Not because we don't fully subscribe to those things, but we want to keep this paragraph high level as drafted and to move away from some of these discussions.

Having said that, we stress the importance of sustainable development in this discourse. However, we want to reiterate that keeping this paragraph high level as currently drafted serves our purpose rather than drill down into listings as it would take us into another discussion altogether. Thank you very much.

Thank you. Ghana Republic of Korea, please.

Thank you colleague and good morning to everyone. I also extend my appreciation to the Khalid and the Secretary for their hard work in facilitating the discussions within this work stream, including the preparation of the revised Colleague Draft Frame Convention template, which reflects the views and feedback expressed by the allegations during the November Plenary meeting in Nairobi. As a general comment, Korea would also support the timing discussion of Article 15 on relations with other agreements, instruments and domestic law, given that given its importance for coherence and legal certainty regarding sustainable development. Article 4 With respect to sustainable development, Korea have supported maintaining the current high level language consistent with the tor and then we consider that any further expansion beyond the existing text may risk increasing complexity. Just like other delegation, including China and Netland has mentioned.

Given the complexity and overlapping nature of issues related to sustainable development and the fact that these matters often require expertise beyond the tax domain, Korea considers that it would be appropriate to maintain high level language in sustainable development. Thank you.

Thank you, Republic of Korea. Finland, please.

Thank you Mr. Chair. Chair, thank you for all the work done and for this new draft template. I agree with the previous comments regarding the importance of Article 15 and that it should be prioritized in the discussions. Working towards a shared understanding on relation with existing agreements and instruments would benefit the negotiations of the Convention as a whole, as then we would have a common context for the discussions.

Thank you.

Thank you, Finland. Zambia, please

Good morning and thank you Chair. And firstly, let me greet the Excellencies and the delegates. It's good to meet once again in New York. Secretariat, Chair, Colleagues, I think we are making some progress looking at where we are coming from Nairobi.

I think it's just a few months that we're in Nairobi. Firstly, I would like to Concur the statement made by Ghana on behalf of the Africa Group. It is our view as Zambia that the text as it stands is fit for purpose.

We note that there's an issue of human rights which we respect, though I think we had extensive discussions on it. Even the time I think we're coming up with a tors. It is our view that this is still something that is kind of covered in the three dimensions. We also note the useful suggestion from the UK for having a mechanism for a review of the three dimensions. But it's our view that I think the mechanism of that and the review can be covered in the article on the Conference of Parties so that then we see how the actual review will be done and not necessarily that that should be be part of the extension of sustainable development article, but it's something that can be covered in the.

In the cop. So we are really comfortable with the way the current wedding is. I submit. Thank you.

Thank you Zambia, Nigeria please.

Thank you Chair. And thank you the colleagues of this work stream. Thank you Secretariat for providing this text for us to discuss this morning. Nigeria, we support the comments that have earlier been made by Ghana in respect of. On behalf of the African Group and for us we recognize the.

The importance of including this article, the article on sustainable development in this Framework Convention. Of course we understand the suggestion by UK and others for some expanded wordings and of course we also understand that we need to have some clarity on implementation of this article. However, we note that we still have opportunity to develop protocols to operationalize this article. So in that respect we note and recognize the need to keep this.

This commitment at high level and we support such keeping the. To keeping them in high level. So in respect of that we for us, we support that. We. We retain this wardens as it is presently and we do not support the inclusion of a reference to human rights.

Thank you.

Thank you. Naira India please.

Thank you Chair. A very good morning to all the delegates. India recognizes the central importance of sustainable development and fully acknowledges its socio economic and environmental dimensions. We also understand the sensitivity surrounding this article as reflected in the extensive deliberations and different perspectives expressed during the negotiations. Our concern however, is not with the socio economic issues referenced in the elaboration of this article, but with the breadth and level of detail being processed at the Framework level.

Sustainable development is a wide ranging concept encompassing issues from gender and social inclusion to environmental protection and economic growth. Attempting to comprehensively elaborate these elements within the Framework Convention risk expanding the article beyond its intended role. India has consistently maintained that the Framework Convention should remain a high level principle based instrument while detailed operational provisions and issue specific elaborations are more appropriately addressed through protocols or subsequent implementing instruments. Introducing extensive elaboration at the Framework level would therefore represent a departure from this established approach. In this context, it's also important to recognize that the Convention is primarily incurred in taxation principles and cooperation on tax matters and its success depends critically on strengthening domestic resource mobilization, particularly for developing countries.

Maintaining clarity and focus on these core objectives is essential to preserve momentum and ensure effective implementation Positions that significantly broaden the Framework risk diluting this focus and geopadizing the progress achieved so far. It is also important to understand that the technical expertise underpinning this Convention lies largely in the domain of taxation. While the socio economic objectives associated with sustainable development are fully acknowledged, tax experts may not be best placed to comprehensively address the full range of social and economic policy issues encompassed under this broad umbrella. Such issues are more appropriately examined in specialized fora with the requisite subject matter expertise. Accordingly, while India remains fully committed to advancing sustainable development objectives, we believe that the article should be retained in a concise high level form without any further elaboration which may be considered in future protocols or implementing arrangements.

Thank you Chair

thank you India, Kenya please.

Thank you Chair and thank you to the CO Lead and the Secretary for all the work that has been done during the intersessional discussions. We align with the position that has been submitted on behalf of the Africa Group as stated by the delegate from Ghana as well as the statements made by Zambia and Nigeria. We appreciate your explanation Kohli that these discussions are starting with the commitments and the discussions on the other articles are soon going to follow. So we support the the order in which the negotiations are going. We also generally support the drafting of this commitment.

The the way the article starts saying taking into taking into account their different capacity capacities. We do support inclusion of those words and we find them anchored in the terms of reference. In fact, the first principle in paragraph nine provides for this principle and says that the objectives of the Framework Convention shall be universal and shall fully consider the different needs, priorities and capacities of all countries. So we're in support of the adoption of those words. We also take the view that the words economic, social and environmental are quite broad and that they can take into account a wide range of factors that different members may want to be included in this commitment.

And so we think that would be wide enough as opposed to listing all the different dimensions or factors that different groups would want included. So the words that are being included in this article, we find them broad enough to take care of those concerns. Thank you, Chair.

Thank you. Kenya Cheer, please.

Thank. Thank you, Mr. Coded, for giving me the floor. And let me express our gratitude to you, the Secretariat and distinguished delegates for their work in the work stream. Czechia would like to join others in asking for the human rights to be included in Article 4 without prejudice to the discussion about principles, because we believe that human rights are highly relevant to taxation. We would also like to join others in asking for a discussion of Article 15 as soon as the agenda allows.

Thank you very much.

Thank you, Chair. Russian Federation, please.

Distinguished colleagues, Dear colleagues, Secretariat, Chairs, co Leads. Thank you for giving me the floor.

We have indeed done very good work. And moving forward, we need to do everything we can to ensure that this work is successfully concluded.

So in our statement, we're not going to touch upon technical circumstances of particular proposals so as to expand the text of this article, broaden it, and those proposals that advance the argument that the text of this article doesn't expand things for the sake of time. We'd simply like to support the position of the African countries. We'd like to support the position of India so as to save time for subsequent discussions.

And it's not the first time that I'm saying we need to make sure that we save time for subsequent discussions. This morning, the Chair, in his statement, and also the asg, said that this is the year in which we need to come up with a text and then next year will be the year for the subsequent adoption of the political decision. We have very little time left, therefore. And the discussions that we're having now, for example, about whether or not to include points about human rights, which of course is something that's very important in every sense. Those are discussions that we've already had.

When we were preparing the Terms of Reference. At that time, we discussed that subject in a lot of detail and now we're using more time to discuss it again. So we would propose leaving the text unchanged and without any expansion as far as the procedure is concerned. But on the technical details of whether that should be done or not has already been addressed in the statements by the previous colleagues that I support. Thank you.

Thank you. Russia, Ireland, please.

Thank you, Chair. Thank you, Kohlid, and thank you and Secretariat for all the work since Nairobi. I'd like to echo our support for this article, but also the comments made by our colleagues from Spain, France, Korea and others on the need for the text to be high level in the Framework Convention. I would also Echo the comments on the importance of drafting Article 15 on relations with other agreements, instruments and domestic law as soon as possible. It will help us not just with this article, but with all of the others as well.

Thank you.

Thank you. Ireland or Pakistan, please.

Thank you, Chair. Pakistan would also like to thank the Chair co leads and the Bureau for their continued efforts and hard work in guiding this process. With respect to the Article 4, we attach particular importance to this provision and support its inclusion in the Convention. However, we support that we retain the current wording which is in line with agreed terms of reference and appropriately maintains a high level balanced approach in this regard. We would caution against expanding this Article to include issues that could in turn open a listing of other issues.

We believe that matters such as human rights are better addressed as overarching principles for this framework. So Pakistan will support the paragraph as originally drafted. Thank you.

Thank you, Pakistan. Laurenberg, please.

Thank you. Thank you, Chair. And also we would like to thank the Secretariat, the CO leads and all Member States for their work on that article. We definitely support it fully as a basis for future work and also we believe that it's high level enough and that it can be completed in a future protocol. Thank you so much.

Thank you. Luxembourg, Belgium, please.

Thank you, Kholid. And I want to also thank you for all the work done by you the Secretariat. We would like to echo what Czechia said on the human rights and on Article 15 on the. We also want to put a question on the first part of the commitment because this seems to be a possibility to weaken the commitment and we want high level commitments, but we still want to reassure that these are real commitments and to us it's not clear how we have to interpret this reference to different capacities and also for us. So it's important that we include include a reference here to human rights and in the Principles.

And also again that Article 15 should be discussed as a priority as mentioned previously by Spain, France, Norway, Korea and Finland also. So this is for us the most important. But in general we can agree with the drafting of this commitment and we see that it's high level. Thank you.

Thank you. Algeria, please.

Merci, M President. Thank you, sir. First of all, I would like to thank you for all of your hard work.

I'd also like to thank the Secretariat and all of the intergovernmental group.

That is to say, during the intercessional work on Article 4, we align ourselves with a statement by the African group. We think that this is in line with the level of commitment we are seeking and it also adds in other elements that are already. We think that adding elements that are already covered elsewhere would weaken the text. Thank you.

Thank you Sierra Leone. Please. Thank you, Chair. Thank you colleagues for work well done. Silent, fully aligned with the African Group and support the commitments and statements made by Ghana on behalf of the African Group and also supported by Zambia, Nigeria and Kenya.

Algeria, Sierra Leone support the paragraph as it was drafted in the terms of reference verbatim. Sierra Leone opposed any inclusion or extension of human rights in this article. For Sierra Leone, Article 4 on Sustainable Development should reflect the realities of least developed countries and support development, pathway and balance, economic growth, social equity and environmental protection. Sustainable development as a development right SIALUN views sustainable development not just as aspiration, but as a development right. Article 4 should explicitly recognize the rights of developing countries to pursue economic growth to reduce poverty and inequality.

The principle of national development priorities allowing countries to determine how sustainability goals are aligned with domestic needs. This is especially important given Sierra Leone's post conflict recovery, infrastructural gaps and reliance on primary sectors such as mining, agriculture and fisheries. Common but Differentiated Responsibilities Sierra strongly supports embedding the principle of common but differentiated responsibilities and respective capabilities within Article 4. This means to developed countries should take the lead in financing, technology transfer and capacity building. Developing countries should not be held to the same standards or timelines without adequate support.

Financing for sustainable development A key concern for Sierra Leone is that sustainable development commitment must be matched with predictable and accessible financing. Article 4 should encourage concessional financing, grant and debt to avoid creating obligations that indirectly increase fiscal pressure on already constrained public finance. Support domestic resource mobilization without undermining social spending, technology transfer and capacity building. Silo emphasizes the sustainable development cannot be achieved without affordable access to environmentally sound technologies. Capacity building for institutions, especially in areas such as taxation, environmental management, energy transitions and digital infrastructure.

Article 4 should therefore go beyond principles and include practical mechanisms for implementation. Thank you.

Thank you, Germany. Please.

Thank you. Mr. Koleet, I'd like to start by expressing our appreciation for and our gratitude for the engagement of the Member States, the CO lead in particular and the Secretariat during the recent intercessional period. Since this is the first intervention at the beginning of the session, I would like to take the opportunity to make some, maybe also kind of a general remark with regard to the Framework Convention. We would like to reiterate the importance of establishing a coherent, balanced and implementable international framework for all Member States. Germany aims in that regard to support further refinement of the Draft with a view to strengthening legal clarity while ensuring administrability and safeguarding the fiscal and regulatory autonomy of States while enabling effective cooperation.

That being said, and this applies to all of the articles that we are going to be discussing, Germany is not in a position to support proposals that would alter the character of the Convention by moving it towards binding self executing commitments. In our view, the Computer Convention must remain a Framework Convention. Secondly, it is crucial in our view that the Convention does not result in any new tax or payment obligation, nor in any immediate or indirect waiver of national tax basis or assessment rights. Before now commenting on Article 4, I would like to join the voices in the room who we have been advocating for a discussion of Article 15 on the relationship of the Framework Convention and other existing international agreements. And we are of the view that it would be good to have this rather sooner than later.

Now, with regard to Article 4, Germany recognizes the important role of tax cooperation to foster sustainable development, including through strengthened domestic revenue mobilization in line with environmental and climate goals. To avoid unintended legal implications, we recommend that the Article ensures three things. First, that it provides guiding principles rather than binding obligations. Second, that the scope of the link to sustainability sustainable development, is clearly defined. And third, that any administrative burdens remain proportionate.

This clarity will support broad acceptance in our view, among States with differing development priorities in that regard. And finally, we consider the proposal made by the UK as a helpful and constructive contribution to that end. Thank you.

Thank you, Egypt, please.

Thank you very much, Mr. Chair for Giving me the floor and extend my thanks for your hard work and great efforts of Secretariat. Regarding Article 4. We support the wording of Article 4 as it is because it is in accordance with commitments of terms of reverence for United Nations Framework Convention on International Tax Cooperation. So we echo the African Group position.

Thank you, Mr. Chair.

Thank you. Israel, please.

Thank you, Chair. And thank you. Thanks the Secretary and the Delegates for providing the draft. We support previous delegates, Spain and Germany that the Convention should include high level commitments. We also think that Article 15 should be discussed as soon as possible.

We think it will help the discussion in other articles. Thank you.

Thank you. Morocco, please.

Thank you, Mr. Chair. Thank you, Kohli. Thank you Secretariat for the excellent work.

We just would like to lend our support to the position expressed by Ghana, Kenya, Algeria, Egypt and others.

So we support having the wording as it reads now and we think we don't need to add anything to it because simply because we think it's broad enough to take care of all the concerns expressed by some member countries. Thank you so much.

Thank you. Pirou please.

Thank you very much, Chairman, for giving me the floor.

We'd like to thank you for providing us with this draft and we welcome the amendments that have been made to the draft Framework Convention. We'd like to thank the coordinators for all of their hard work on Article 4.

Peru agrees with how this article has been drafted. We think that this is high level language and we agree with it. Thank you.

Thank you. Portugal, please.

Thank you very much for giving me the floor. Mr. Kolitz, let me start by showing our appreciation for all the hard work that you have done collectively with the UN Secretariat and also the Member States during the intercession period that led us to the document that we have in front of us, which is a good starting point for our discussions. I have to signal that as a general comment, I have to signal that we are one of the Member States that sees the importance of discussing the article 15 as soon as possible in our agenda so that we can have a clear picture, or let me say, a framework where these commitments will be binding and will be developed so that we can give a more clear opinion in respect of the drafting that we have in front of us. The relation is for us obvious and we would like to take out some exploration of these facts in respect of Article 4. I would like, by saying that we fully echo what Germany has said in respect of the high level of our commitments should have and why they should be so high level.

Germany said it in general, and we think that it is something that also applies to Article 4 in the same sense that that the distinctive representatives of Spain, France and India and others have said in respect of this article 4. It leaves us with a problem. In fact, there is no reference to human rights in this draft that we have in front of us. And it somehow documents the complex relationship that this Framework Convention is having with the reference for human rights. That for us is not that complex.

But in fact it has been difficult to ascertain why and how this could be in the Framework Convention. I believe that probably it's a problem that we have to face and resolve. Probably not here in this commitment. Probably it could be a matter for the principles that we have not discussed yet. The same way that what I've understood this morning.

The same can be said in respect of the beginning of the Article, taking into account their different capacities. And as long as this is a principle of the Framework Convention, probably we could streamline this article and treat this also in the principles area. Thank you.

Thank you, United Kingdom, please.

Thank you, Chair. As it's My first intervention of the Chair. I wanted to also echo colleagues in thanking you and the Secretariat for all of the work that has gone in into preparing this meeting. As it's our first intervention and as other colleagues have brought up Article 15, I just wanted to kind of lend the UK support to that. I think it's obviously incredibly important that we have that article and we have that article promptly.

We have previously called for this to be articulated. Articulated. And I think it's. And I think we'll come to this as the session goes on. But I think it's quite challenging for us to be able to engage with the wider articles of the Draft Framework Convention without seeing that, because there is an inherent interaction there.

So, as you yourself noted at the start of the session. So, yeah, we would urge. Urge that article to be kind of tabled as soon as possible within this process as it concerns Article 4. Everyone, of course, has seen the UK's written comments and so I simply wanted to note that, you know, we do consider this is an important issue. We would like to see it elaborated on further as we put in our written comments.

Thank you very much.

Thank you. I don't see any more Member States, so we can move to the stakeholders. YFG, that's European Youth.

Thank you, Mr. Chair, distinguished delegates. Youth participation in this process is important and increasing such strong participation from young people and youth organisations is an essential and underutilised asset for this Committee. We engage in this process because we believe that the Convention has immense potential to unlock public revenues for social and environmental action, reduce inequalities and hold corporate and wealthy polluters to account for their environmental damages. Our mandate in this room comes from the General assembly, and it's a straightforward one.

We must build an international tax system for sustainable development. This starts now, not in a future hypothetical protocol, now in the Convention. And what better way to start than by operationalizing the polluters pay principle? If the UN Tax Convention does not enshrine it, we are missing a fundamental opportunity. This principle is long established in international, regional and national frameworks, from the Rio Declaration to the Treaty on the Functioning of the European Union.

Environmental responsibility is not optional. It is a legal and moral duty. And it must therefore be at the core of the architecture of an international tax system worthy of the 21st century. The second cornerstone of international environmental and climate law that is lacking from this draft is the principle of common but differentiated responsibilities and respective capabilities. It reflects a simple truth.

Countries differ in their capacities and of course, in their historical responsibilities. And there's no reason for this principle to be absent from this convention. Distinguished delegates in Nairobi. My colleague pointed out that this article had only three words per sustainable development goal. Unfortunately, this has not changed.

We are concerned. Young people are watching. Will you be able to deliver? So I ask which Member States will have the courage to present a negotiating text with substance? As I say that, let me not be understood as only making a statement.

It's also a hand of cooperation. We are here to help and to work together. Young experts on financing for development sit here in this room. We have the tools international law and intergovernmental declarations from the Paris Agreement to the compromise of De Sevilla which bind Member States are full of commitments and language to build a better article and a better future for our generation. Children and youth are not just a demographic.

We are the long term intergenerational stakeholders of this process who live the longest with the context, the direction and the decision set over these next two weeks. A strong Article 4 is your promise to us. This promise cannot be empty, so it's time to draft. Thank you.

Thank you, Cesar. Please.

Gracias, Senor. Thank you. Co Chair. I'm speaking on behalf on. On behalf of the Centre for Economic and Social Rights and other civil society organizations present in the room.

The current article on sustainable development is the only commitment that is practically identical to the terms of reference. The declarative nature of the article does not contradict the importance of sustainable development, given the urgent need for elements of development to be financed appropriately. Now, limited ambition on this commitment would mean wasting an opportunity to enhance consistency between policies. Member States have already shouldered more robust responsibilities in terms of tax policy and sustainable development in other fora and other legal instruments, such as international human rights treaties that compel Member States to maximize the resources available to uphold these rights. Many Member States have acknowledged the link between financing public services and sustainable development.

They have signaled the importance of consistency with other frameworks and the importance of reporting back on the way in which these commitments have been implemented. In this vein, while acknowledging States have the responsibility to align policies with their own needs, there are four goals that need to be met. First, there has to be a broad approach to sustainable development, linking it with the attainment of human rights principle, socio economic and cultural rights, financing of public services and addressing intersectional and structural inequalities. Two States need to report back periodically on how they are implementing this article, ensuring the participation of all relevant stakeholders. Three Member States need to take measures to promote consistency between tax policy and sustainable development in relevant UN frameworks and lastly, we need to assess the impacts, including extraterritorial impacts, of tax evasion on State's ability to attain sustainable development.

Thank you.

Thank you. We have Greenpeace please.

Stakeholder 1 Greenpeace.

How do I get. Hello. Thank you. Chair it is worth remembering that from the latest written submissions alone, parties from across multiple regions have expressed clearly that they want more substance to be added to the sustainable development article. Six parties said that they want more detail on how the commitment in the article will be met.

One party supported text on new forms of taxes to raise extra revenue for the Sustainable Development Goals. One submission supported ensuring that a link is made to structural transformation in developing countries and one party called for embedding the Polluter pays principle to deliver accountability and fairness in international tax cooperation. There were also relevant verbal statements from a further three three countries at Inc, three verbal and written statements from a further five countries at Incs 1 and 2, and several important comments from the floor just now. It's therefore deeply disappointing and a concerning reflection on the process that the latest draft template text reflected no changes to this article compared to the draft published in October. Furthermore, the terms of reference requires the inclusion of environmental policy acts aspects which is not in the draft.

The current tax actually also fails to reflect the growing global political pressure for ambitious action on progressive environmental taxation. For example, the COP28 climate outcome agreed that new taxes need to be established to implement climate action. The International Court of Justice Advisory Opinion on Climate Change last year could concluded that governments must use all policy tools available to them, including taxes, to align polluting corporations with global warming limits. And we of course had the Financing for Development outcome last year that committed to promote progressive taxes on environmental contamination and pollution. In this light, we urge that Article 4 is strengthened.

The current text does not give a clear enough mandate to guarantee that tangible global mechanisms will actually be established to unlock the hundreds of billion dollars necessary to support resource mobilization through taxing corporate and super rich polluters. This strong mandate is crucial to raise funds to invest in climate resilience and essential public services, particularly for the most vulnerable countries and communities. We need a clear commitment that parties shall to deliver nationally and internationally progressive environmental taxation in line with the polluter pays principle and the principle of common but differentiated responsibilities and respective capabilities. Let's not forget the costs of climate change are already racking up to hundreds of billions of dollars per year hitting communities across the world. A typhoon survivor, Trixie L. From the Philippines recently told me her personal story.

After the typhoon struck, she was left with no support. She had to feed her family on dead animals to survive. And she had to take out huge amounts of personal debt to rebuild her home. If we don't strengthen Article 4 today, these devastating costs won't just go away. Parties will actually in fact be deciding that individual households have to pay instead with little or no support, or that essential services like education and health will have to be cut even further.

We must not settle for the inadequate text that is currently before us. Thank you.

Thank you. And a quick comment before. Since this is a house of records, I will be grateful that when we are given facts and figures, we do so based on fact. Thank you. Cy, please.

Thank you. Chair, I take the floor on behalf of the FFD Children and Youth Constituency of the Major Group for Children and Youth as the General assembly mandated Children and Youth Constitution constituency, We represent over 20,000 youth organizations in over 50 intergovernmental and 200 multi stakeholder processes. Distinguished colleagues, over 57 children and youths are participating in the fourth session of negotiations for the UN Tax Convention throughout the two week period. This is the largest children and youth participation to date in these negotiations and for any tax related intergovernmental bodies. We therefore would like to first take this opportunity to express our deep appreciation to the Secretariat and the Bureau for the Committee for their tireless facilitation of multi stakeholder participation.

We also thank Member States that have supported multi stakeholder participation this morning who reiterated the importance of public participation through the amendment. We call for all other Member States to join this positive movement as well. Mr. Chair, the draft for Article 4 states, I quote, pursue international tax cooperation approaches that will contribute to the achievement of sustainable development in its three dimensions, economic, social and environmental in a balanced and integrated manner. Children and youth firmly believe that the social dimension of society, sustainable development in alignment with SDG 16 and 17 includes the question of meaningful and effective multi stakeholder and intergenerational participation.

Therefore, we must stress the importance that representatives of stakeholders and right holders must not be left behind. Finally, we suggest that the article be appended to add, I quote, in a balanced, integrated and inclusive manner, in partnership as appropriate with Agenda 21, major groups and other stakeholders. We would also like to join others in calling for the inclusion of the term human rights in the article as well. Distinguished colleagues, the Major Group for Children and Youth, with our other members present in this Committee, will tirelessly work to ensure that this process remains open, inclusive and grounded in intergenerational equity and collaboration, as we believe that this is the foundation of true sustainable development. I thank you.

Thank you. Before we go on, stakeholders, we have a member states, Saudi Arabia, please. Thank you so much, Daniel, and apologies for coming in a little bit late. I just want to first wish you all a happy New Year. For those who haven't seen yet, and just wanted to add my voice to the delegates who came before me on Article 4 on sustainable development to keep the article as it is without expansion to align it with the torque, for the reason that while we see the issue of these three dimension issues, we believe that these are addressed in the relevant fora in the UN where such work are being carried on.

Thank you. All right, thank you. Canada, please.

Thank you, Chair. Thank you to you and the Secretariat for these revised drafts. I also wish everyone a happy New Year. And unlike others in the room, I'm enjoying the relatively balmy temperature here in New York. Probably the only one that can say that, at the same time acknowledging that it is rather cold here in New York as it has been in Ottawa.

But back to the particular issue at hand. I think in general, as we have previously stated on a number of occasions, Canada supports high level commitments to be contained in the Framework Convention. And I think it was well set out by the delegate from Germany in respect of the reasons for seeking high level commitments, and we agree with those. I think in that vein we can support the current drafting of Article 4, given that it is high level in nature. I think that is not saying that we don't think there are other important aspects such as human rights, but we think that there are other places, perhaps in the conventions or other fora, where that can more specifically be dealt with and we would support this drafting.

I will also lend my voice to the support that we need to discuss Article 15. And I would suggest it would be helpful if we could do that this week. I think it will come up more directly in the discussion of the subsequent article. And so I'll discuss it in more detail in relation to the next article. Thank you.

Thank you. Feminet, please.

Thank you, Chair. I speak speak on behalf of the African Women's Development and communications network, FEMNET, the Africa CSOs working group on the UN tax convention, and the Tax and Gender Working Group convened by the Global alliance for Tax Justice. Distinguished delegates. For decades, governments have committed to advancing gender responsive taxation within their jurisdictions. These commitments are firmly grounded in existing international frameworks, including among others, the Convention on Elimination of All Forms of Discrimination Against Women, CEDAW, and most recently the Compromise de Sevilla, in which states commit to advancing gender responsive taxation.

By removing discriminatory tax provisions, assessing the gendered impacts of tax measures, ensuring equal access to tax benefits and credits, and structuring revenue systems to advance substantive gender equality. These commitments reflect government's recognition that tax systems are not gender neutral. The reality is that the global tax system as it currently exists is failing. It is shaped by intersecting systems of colonization, patriarchy, imperialism, modern slavery and neoliberal capitalism, systems that have historically concentrated wealth and power in the hands of a few while deepening inequalities for many, particularly women and other structurally marginalized communities, including indigenous people, people and people of African descent. We therefore reject the narrative that frames taxation as merely a technical issue.

Tax is political, it is gendered, and it is fundamentally about justice, rights and equality. We note with concern that despite the extensive discussions and positive reflections from some Member States during the last session in Nairobi, gender remains omitted from the Convention text. In this context, we strongly Recommend that Article 4 of the Convention includes an explicit and substantive clause on gender equality, particularly calling for the First, a commitment to ensuring that fiscal systems are fully aligned with Member States existing obligations to progressively realize human rights and gender equality to the maximum of the available resources. This should include explicit references to reducing gender inequality within and among countries and to public financing of gender responsive public services. Second, a clear commitment to ensuring that national tax systems and international tax reforms rules actively promote gender equality.

This requires explicit gender sensitive language, recognition of the differentiated impacts of tax policies on women and men and the elimination of gender bias in tax legislation and administration. Third, a requirement for strong transparency and accountability mechanisms, including the system systematic collection and use of gender disaggregated data to monitor and assess progress on gender equality and tax commitments. Fourth, the article on Sustainable Development should obligate each Party to report regularly on its performance in implementing these commitments in line with deferring national needs, priorities and capacities as outlined in the terms of reference. The future Conference of Parties should also undertake a comprehensive review of implementation of this article as a standing agenda item at each meeting. In conclusion, a truly feminist tax system is not simply about removing explicit discrimination.

It's about deliberately designing policies that close gender gaps and redistribute power and resources. Tax justice is gender justice, tax justice is gender justice and gender justice is the foundation of a fairer world. Let us seize this opportunity to build an equitable global tax system that truly serves all.

Thank you, thank you ilo Please.

Thank you Chair and Kooleads for giving us the floor. We welcome the Co Leads Draft Framework Convention Template published on 22 January on Article 4, we would like to note that at its 79th session, the General assembly recognized that the development of a framework convention would help accelerate the implementation of the Compromiso de Sevilla and the 2030 Agenda for Sustainable Development. In this context, we invite Member States to consider an Article 4 in which key elements of sustainable development are further articulated. Since eradicating poverty in all its form and dimensions is essential to sustainable development, we wish to underscore the importance of including universal, universal social protection. Historically, social protection in combination with progressive taxation has been the most relevant reliable policy lever to reduce poverty and mitigate inequalities.

In particular, it would be important to stress in the article the role social protection has in promoting inclusive growth and in strengthening domestic tax revenues. I thank you.

Thank you, Jamaica, please. Thank you for giving me the Chair again.

I just wanted to. I've been listening to the discussions and reflecting on my earlier statements on behalf of Jamaica and why it is that we are not completely satisfied. And I just want to say this, Chair, we fully understand the complexities of drilling down into the dimensions of the Sustainable Development Goals, and we also recognize that if we are keeping the statement at a high level that, you know, it would not be maybe appropriate or reasonable to go into each of the Development Goals. But here is our. Our issue, Chair, I think to a certain extent, in reading the room and the responses, I get the sense that we are not likely to go beyond just merely touching the surface.

We would have wanted to see language that spoke more directly to the issue of international tax cooperation and the, the link to these goals. What we believe will happen, Chair, is that we will not go beyond these words. We are being told that there will be a protocol at some point, there will be the conference of parties. But as we speak, Chair, the issue of climate change and environmental taxes. Environmental issues are very live to some countries, and I don't need to mention my own and our recent experience.

And of course, when that happens, in our case, it was 40% of our economy that disappeared. And so we are now back into the spiral and the boils of debt financing. And perhaps that is what we ought to be discussing. Because you see, as long as we delay the issues concerning the relationship between international tax cooperation and environmental issues in particular, then it means that countries who are being impacted will just continue every six months to be going through this whole issue of trying to rebuild before you are affected by yet another climate disaster. And so, Chair, I think we are going to go along to get along.

I think that seems to be our fate. But it really brings to mind the part of a song that my countryman Bob Marley did sang. And in it he says that well, for us sustainable development and I'm adding my own mix to it, will just be a fleeting illusion to be pursued but never attained. And we regret that this convention would have missed the opportunity to be revolutionary and to assist countries in actually attaining sustainable development. Thank you, Khalid.

Thank you. ICC. Please.

Thank you, Mr. Khalid. On behalf of the International Chamber of Commerce, representing the voice of the global business community, we would like to commend the work undertaken by Workstream one on the Framework Convention in relation to Sustainable Development. ICC remains firmly committed to to achieving sustainable development and the Sustainable Development Goals. Achieving these goals relies in no small measure on countries ability to attract long term productive investment for businesses. Predictable and stable tax rules are a foundation component in investment decision making.

Enhanced uncertainty not only facilitates cross border investment but also supports job creation and broadens the taxable base over time by fostering sustained economic activity. Ensuring coherence and clarity in the emerging Framework Convention is therefore essential to enable governments to mobilize sustainable revenues while supporting private sector contribution to development. Against this backdrop, we note with concern that no drafted article yet addresses the relationship between existing treaties and the Convention and its protocols. So basically, Article 15, such a provision will be indispensable for understanding how implementation will operate in practice and for providing the legal certainty taxpayers will require as they adapt to any new obligations in order to remain compliant. Similarly, we urge caution regarding calls for negotiation of existing treaty networks or the pursuit of treaty override as referenced in discussions on Protocol 1 last week during the multi Stakeholder Dialogue.

These approaches risk creating widespread uncertainty for established supply chains, especially at a time where geopolitical instability is is already placing considerable strain on global business operations. In conclusion, ICC reiterates its support for a Framework Convention that strengthen international cooperation while preserving the predictability essential for investment growth and sustainable development. We stand ready to contribute constructively to the next stages of the negotiation and we encourage continued dialogue with the business community to ensure that the resulting instrument is both ambitious and workable in practice. Please. Thank you.

Thank you. We now move to Ataf.

Thank you, Mr. Kohlid for giving us the floor. We'd like to start by commending the work of this work stream in bringing us the draft in time for discussion. And further, we'd like to align our commentary with that of the Africa Group and and its members. We fundamentally believe that the language used in this article, as it is, is sufficient and reflects the discussions that we've had as member countries and stakeholders in drafting the terms of reference. We further believe that expanding on this article risks taking us away from the core mandate of providing sustainable development for developing countries through the use of domestic resource mobilization in the form of international tax cooperation and therefore we urge members to carefully consider retaining the text as it is as that reflects the terms of reference.

Thank you.

Thank you. Icc Mexico please Mr. Colley, good morning.

ICC Mexico is pleased to take the floor today and state that we aligned the intervention delivered by ICC Global which articulates the shared priorities of the international business community. We appreciate the opportunity to complement those remarks with perspectives from the Mexican private sector. Across Mexico and the broader Latin American region, companies are operating in an environment marked by uncertainty, evolving supply chains and shifting global economic conditions.

In this context, our members underlines that predictability and clarity in international tax rules are essential for planning long term investments and maintaining stable business operations. As in Mexico, it's committed to advancing to sustainable development goals and we recognize that tax certainty is an important enabler of sustainable development. When tax frameworks are stable and coherent, businesses are more likely to undertake long term projects that generate formal employment, make regional value chains stronger and support broader economic activity. Over time, this contributes to a more resilient and sustainable tax base, an outcome that benefits both governments and societies. As international Cure of justice stated in the Gachiko Nagimados case, economic development must be reconciled with the protection of collective goods.

This balance is hindering in the concept of sustainable development. Remarks Legitimate and effective regulatory frameworks over time in view of this, ICC Mexico wishes to highlight the importance of including a clear provision on how the Framework Convention will interact with existing and regional tax treaties for Mexican companies engaged in trade within North America, Latin America and beyond. Understanding how treaty obligations will align with any new international rules, it's essential for compliance and operational continuity. Greater clarity at this stage will help having a better understanding of how the Convention will be implemented and how this will reflect in the local and regional context. We also echo ICC Global's call for caution with respect to wide ranging treaty renegotiation or treaty override.

As mentioned in discussions related to Protocol one, sudden and extensive changes to existing trade networks could introduce uncertainty for the businesses that operate across multiple jurisdictions. In particular, at a moment when global supply chains remain fragile and investment decisions require stable and reliable frameworks. In closing, ISIS in Mexico reaffirms its support for an outcome that makes international cooperation stronger while ensuring the stability and clarity needed for economic activity that contributes to sustainable development. We Stand ready to continue engaging constructively with all stakeholders and work closely with ITC Global to help shaping a Framework Convention that is ambitious, practical and responsive to the realities of diverse economies. Thank you.

Thank you, Belize. Please.

Thank you, Kholid, and thank you for the work that has been done. As this is the first time Belize is actually formally engaged in these issues, I want to express my delegation's full support to see in a successful outcome. We look forward to engaging more fully as we enter this. As we pivot into this stage towards drafting these critical documents. We have appreciated the views that have been shared over the course of the three foregoing sessions and we also appreciate the views that have been shared in this context.

Specifically, in regards to Article 4, we do want to underscore that Belize's approach will be holistic. It aims to look at the Framework Convention as a whole and look to specific principles in relation to equity, sustainable development and an integrated, people centered approach for the development of the Convention. In this regard, we'd like to highlight and support support what our colleague from Jamaica has recently stated about the need for the Convention or the Framework Agreement to anchor the linkage between sustainable development and international tax cooperation. Thank you. Right, thank you.

We now have sticker fall as the Bombay Chartered Accountant Society.

Thank you. Chair. The words economic, social and environment are very wide in nature and yet open to subjective interpretations. And some or many may believe that these words are not sufficient. It may not be possible or desirable to include everything in the text of an article and the possibility of including other important aspects elsewhere may be considered.

Let's look at what's happening in other documents. OECD and UN Model Conventions have a detailed commentary. BEF's MLI has a detailed commentary. OECD Pillar 2 Rules has a detailed commentary. Why don't we consider something similar for Framework Convention?

So the question is, would there be a commentary or explanatory statement for the Framework Convention? If yes, the possibility of including additional aspects in the commentary may be considered and links may be created for the work done in other forums on these other aspects. This will also open a window for countries to give their reservation positions on the additional aspects included in the commentary. If the window of commentary is open, several other comparable issues on other articles which may arise in the course of discussion, negotiation of this Framework Convention may be addressed in the commentary. Thank you.

Right, thank you.

I don't see any more requests for the floor.

There's been quite a lot of questions on Article 15, but I believe that before we bring any somebody I Think some. Some state suggested that we should discuss it before we leave here. But I believe we all agree that if we've not discussed something at the intersectional meetings, we don't discuss it at the plenary because we need to have some initial discussions. So the Comments on Article 15 are well noted. We will look for the appropriate time to have that discussion and then we can continue.

Now, the okay word of you.

Sorry, do I have the floor?

Yes, you have the floor. Go ahead.

Thank you very much. My apologies.

For some reason I did not have a name card. My name is Atia Waris. I'm the UN independent expert on foreign debt and international foreign national obligations. I have five points I'd like to make which I hope will be useful to the conversation. We have mentioned countries that are going through a lot of climate distress.

But I would also like to add in the issue around war and conflict, we have more countries now under war and conflict than ever before. And in my report to the UN General assembly on issues of peace finance, that particular link has become more and more important in this context of these two vulnerabilities. This particular treaty or frame of convention is intended to address vulnerabilities and inequalities. And if these are the two inequalities that we see are the deepest in the world, then firstly, between these two articles that we are referring to 15 as well as 4, what we notice is international commitments have already been agreed to. My concern is a debate and a discussion around treaties that have already been committed to by the entire world really should not be brought back into the table again.

And as a result, this maintains what many have referred to as predictability and certainty. Predictability and certainty means that international treaty obligations already in place should be maintained and of course referred to in this particular space. The third point I would like to make is that inequality is a core part of this treaty. As a result, we need to ensure that each clause is very clear in how it addresses inequality. And as a result, so should sustainable development.

So what would be inequality? From the perspective of sustainable development, it would include the fact that Member states are often have to resort to debt agreements when they are unable to collect taxes, which means a reduction in the number of debt agreements because of an increase in the amount of tax revenue collection will actually result in a lessening of this inequality. And if I move across to issues such as credit rating, fatf, as well as questions around peace and its intergenerational implications which have already been mentioned, then what you start to see is that these are your markers of sustainable development, but from a fiscal perspective. In addition, I would like to point to one other principle, which is that of international cooperation and assistance. The language of international cooperation within the international human rights framework is of international cooperation and assistance.

And as a result this will be a reflection of a reduction in. In inequality. And I would like to point you to my report to the Human Rights Council in March of this year, which is already publicly available, that actually unpacks that particular phrase. Finally, I would hope that many of the conversations that we are having around the issue of legal obligations can be better addressed from the Office of Legal affairs of the United nations. And I hope they are in the room today and if they are not, that they be made to be present because this is critical.

I thank you very much for your time.

Thank you.

Right, I think I can now go on. Okay, so we can conclude the discussion on Article 4 for now. I'm sure at some point later we'll come back to it. The next article will be five. But I believe that there's a lot we have to see on Article 5.

We stand now we might have to cut people somewhere along the line in order to go for lunch and come back. People might lose their train of thought. So I will suggest that we take our break now and then rather when we come back, then we can move straight into to the discussion so that the flow of thought will continue. So that I'll hand over to J. So the.

For his remarks before for lunch.

Thank you, Daniel, and thanks to all the delegations for your participation. And yes, we will come back in the afternoon session with a fresh mind to go through one of the most critical articles. So now we are gonna close this meeting and see you all again in the Same room at 3pm thank you all and have enjoy your lunch.