Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation - First Substantive Session 2025, 1st meeting

Good morning everyone.

I declare open the first 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. I am pleased to welcome you to the first and second sessions of the Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation and its two early Protocols. We stand at the outset of ambitious, fast moving process with 10 sessions I call them 10 opportunities ahead of us to shape a new era of global tax cooperation. The path to success demands not only our wisdom and expertise, but also our full engagement, focus and collaboration.

These Plenary meetings are a pivotal moment that sets the tone and direction for our work. The feedback gathered during these meetings will serve as a compass for our technical work streams and shape their proposals to be presented to the General assembly in 2027. I noted that hundreds of Member State representatives had attended the work Streams daily meetings that took place since May 2025 with a very active interaction on an genuinely equal footing basis. The process is designed so that every Member State has the right and the opportunity to attend, to co lead and to contribute to any of the work streams of without exceptions.

Even for those Member States unable to join every intersectional discussion, there are ample opportunities to review, comment and influence the outcomes. These processes of Member States consultation and discussion in bilingual sessions are designed to include everyone, leaving no one behind. Furthermore, rounds of public consultations are built into our roadmap at each milestone, ensuring that all voices are heard, including those of civil society, the private sector and other stakeholders. We are also making use of interactive virtual meetings to break down barriers and widen participation even further. The process is designed to guarantee maximum inclusivity and efficiency.

We are determined that no single country or group will dominate or steer our discussions. This is a process of genuine partnership built on respect, transparency and equality excellences. The work of this Committee follows a phased approach, starting with identifying gaps and issues with delivery of the final and ends with the delivery of the final text of the Framework Convention and the two protocols. Those are our final products that we need to focus on. The CO Leads notes released on 27th of June capture the breadth of the rich and substantive discussions held throughout our technical meetings to identify the gaps.

I urge you to treat them as a strategic starting point for our deliberations over the coming days. Additionally, the fruitful input received from international organizations, civil society, academia and the business sector bring valuable perspectives to our Work Excellencies. These sessions present a significant opportunity to advance in this process. Let us maximize these sessions and ensure they drive meaningful progress. Every contribution, every exchange is a building block in what we are constructing together.

I urge you to remain focused, engaged and purposeful in our deliberations. Finally, I want to express my deep appreciation to the colleagues for their leadership and to all the Member states and the stakeholders for their continued engagement. The diversity of perspectives brought to this process and is essential to building a more inclusive, balanced and effective system of international tax cooperation, one that reflects the needs and priorities of all jurisdictions.

Before continuing, please allow me to announce that as part of this works program, there will be no plenary meetings on Thursday, 7 August. Instead, several important engagements will take place regarding the planning for Regarding planning from here to Nairobi and in particular, there will be a dialogue with civil society from 145 to 245. These touch points will help ensure continued alignment and momentum across all areas of our work.

I now give the floor to Ms. Sherry Spiegel, Director of the Financing for Sustainable Development Office of the Department for Economic and Social Affairs. The floor is yours.

Thank you so much. And thank you, Chair. And it is really my pleasure to welcome everybody here and to see a full room as we start the discussions over the next two weeks.

As you all know, we just completed the fourth International Conference on Financing for Development in Sevilla, and the Sevilla commitment was approved by consensus and Member States committed to continue to engage constructively in the negotiations on the United Nations Framework Convention on International Tax Cooperation and its protocols and encourage support for the process. The commitment speaks directly to the broader significance of the importance of this Convention. It reflects a shared understanding that international tax norms must evolve to keep pace with global changes. They need to be flexible and resilient, but at the same time, they must serve all Member States and promote sustainable development. As you know, tax is not an end in itself.

It's a means to an end for sustainable development. And the idea that international tax cooperation must support sustainable development was powerfully affirmed in the Sevilla Commitment. The commitment recognizes that in a globalized and increasingly digitalized world, domestic efforts must be complemented by international cooperation to effectively mobilize domestic revenues, and that existing international tax rules often do not fully respond to the needs, priorities and capacities of developing countries. So the Framework Convention that we'll be discussing in the next two weeks can contribute to sustainable development by ensuring that tax rules reflect the needs and priorities of Member States and by supporting them in their efforts to mobilize domestic resources to support sustainable development.

As this is the first substantive session of the process, today marks a significant milestone in this process. There is actually two substantive sessions, as you know, back to back, and that we're opening today. They're really essential steps in the journey toward drafting the United Nations Framework Convention on International Tax Cooperations and the initial protocols. Allow me to briefly recount how we have reached this point Point Our journey began in 2002 with a mandate from the General assembly to strengthen international tax cooperation. This was followed by the General assembly establishing the ad hoc committee that produced the terms of reference for the Convention and then establishing this negotiating committee.

And following our organizational session last February, the International the negotiating Committee began its substantive work. As the Chair noted, it's already put in place robust technical work plan which is structured around three thematic work streams, each tasked with drafting one of the legal instruments envisioned by this Process. Work Stream 1, as you all know, focuses on the Framework Convention itself. Work Stream 2 on the protocol on Taxation and Income from Cross Border Services in an Increasingly Digitalized Economy and work stream three on the Protocol and Prevention and Resolution of Tax disputes. In May and June, Member States met almost daily to develop the issues Note that we will be discussing over these next two weeks.

And the level of engagement, as the Chair noted, has been very high, with often over 100 delegates from all regions connecting the so I very much. I think we're all very much look forward to the productive and successful session in the next two sessions coming forward and one that is really focused on technical discussions and substantive discussions on the issues. And let me close by expressing my sincere appreciation to all Member States for your active participation and particularly to the Chair and to the CO leads for their leadership in this process and very much looking forward to the discussion over the next two weeks.

Thank you.

Now the Committee will resume its consideration of Agenda Item 1, entitled Election of Officers. In accordance with General Assembly Resolution 79 235of 24th of December 2024, the Committee shall elect 18 Vice Chairs and Rapporteur elected on the basis of equitable geographical representation and taking into account gender balance. I have been advised that Ms. Marta Juanita of Colombia, Vice Chair from the Group of Latin America and Caribbean States, has tendered her resignation. I have received the nomination of Ms. Claudia Lucia of Brazil for the position of Vice Chair. May I take it that the Committee wishes to elect the nominee by acclamation as 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 just concluded this statement stage of its consideration of Agenda Item 1. The Committee will resume its consideration of Agenda Item 3 entitled Organizational Matters. Members will recall that by its decision 2 taken on 3rd of February 2025, the Committee adopted the program of work for its sessions on the understanding that it might be revised during the sessions as needed. In this connection, the revised program of work is contained in document A AC 298 CRB 14 Rev.

1, which has been distributed to delegations via Edelegate and is available on the website of the Committee. Members will also recall that by its decision 3 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 institution and the private sector and other stakeholders.

In this connection, the Committee has before it drafted decision A AC 298 CRB 16 entitled Participation of International Organization, Civil society and other relevant stakeholders and Draft Amendment A, AC298 CRB18. I now give the floor to the representative of Germany to introduce the draft amendment.

Thank you Mr. Chair. Distinguished delegates through document A AC 298 CRP 15, the secretariat provided information on new applications for accreditation from intergovernmental organizations, civil society organizations, academia institutions, private sector organizations and other relevant stakeholders. The document indicates that objections were raised during the non objection procedure procedure in relation to six non governmental organizations in the draft decision of 31 July 2025 contained in document A AC 298 CRP 16. These same six non governmental organizations are not listed among the stakeholders proposed for admission.

Based on the available documentation, it is not clear whether and if so how the respective objections were substantiated, nor is it apparent by whom the objections were raised. At the same time, the document CRP 15 states that valid applications were received from the six organizations in question. Against this background, the reasons for their exclusion remain unclear. Germany is committed to ensuring the inclusivity and transparency of the work of the Intergovernmental Negotiating Committee. In this context, Germany strongly supports inclusive and meaningful multi stakeholder engagement.

Guided by these considerations, Germany advocates for the extension of the list of admitted stakeholders to include the six non governmental organizations concerned. The amendment submitted by Germany served this very objective. Thank you very much.

I thank the representative of Germany and now I give the floor to the Secretariat.

Thank you Chair. I'll dress co sponsorship of draft amendment CRP 18. If any countries not listed on CRP 18 wish to co sponsor the draft amendment CRP 18, please press the microphone button. Now I see Croatia, the Kingdom of the Netherlands, Poland, New Zealand, Czechia, Portugal, Finland, Luxembourg, Denmark, Austria, Ireland, Malta, Slovenia, Switzerland, Italy, Belgium, Norway, France, Latvia, the United Arab Emirates and Canada.

If I have read out your name to kindly unpress the microphone button. If I have not to do is quite a list. Bear with me. I see the United Kingdom.

If any other countries not read out wish to co sponsor draft amendment CRP 18, please press the microphone button now.

Thank you, Mr. Chair.

I thank the sketch. Delegations wishing to make a statement in the explanation of vote before the vote on any or all of the proposals, including the draft decision and the draft amendment under this item are invited to do so now in one intervention after action on all of them, there will be an opportunity for explanation of vote after the vote on any or all of them. I remind delegations that statements in explanation of vote are limited to five minutes.

Distinguished representative of Canada

thank you, Mr. Chair. Canada firmly believes that the meaningful inclusion of a broad range of stakeholders, including non governmental organizations, civil society organizations, academic institutions and the private sector and UN processes enhance the quality and legitimacy of outcomes restricting participation of individual organizations should be limited to exceptional cases and by decision by the entire membership and based on the point put forward by Germany. Unfortunately, we do not have the information at this point. The initial selection of organization by the Secretariat is based on an established procedure and has been done for many UN processes.

This process deserve our trust and support. In this context, Canada is pleased to support the German amendment and encourage all states to support it as well as we value civil society, organization, academic institution and private private sector's voice in this process. Thank you.

Thank you, Distinguished delegate of.

So, we will now proceed to consider draft decision CRP 16 and the draft amendment CRB 18 before we take action on the draft decision. In accordance with Rule 130 of the Rules of Procedures or Procedures, the Committee shall first take a decision on the draft amendment CRP 18.

May I take it that the Committee wishes to ADOPT Draft Amendment CRB 18?

I hear no objection. It is so decided.

Since the draft amendment is adopted, we shall proceed to take a decision on CRB 16 as amended.

May I take it that the Committee wishes to adopt a draft decision CRB 16 as amended?

I hear no objection. It is so decided.

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

Distinguished delegate of Turkey thank you.

President 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 UN. In line with the principles and proposals of the UN Charter, Turkey supports only those NGOs whose work genuinely contributes to the constructive progress of the Committee's mandate. Advancing fair, inclusive and effective international framework for tax cooperation.

We are not supportive of those NGOs that are engaging in activities that run counter to the proposals and principles of the UN Charter and engage in politically motivated acts against some Member States. Yet the amendment proposed today unfortunately allows a group of Member States to overwrite valid objections without adequate understanding and security of those NGOs activities, thereby transforming this matter into a potentially politicized one. As a matter of fact, the proponents of this amendment do not have detailed information on the objectives and activities and financing of those NGOs that are objected by certain Member States. Furthermore, no proper justification has been given on which grants all those NGOs and stakeholders that are objected would be critical to the work of the Intergovernmental Negotiation Committee process.

For the purposes of transparency. The to ensure an informed decision making, we would have preferred to be notified in detail on how those NGOs and stakeholders plan to meaningfully contribute to the work of the Committee in future. Our modalities should be designed in a way that all Member States are informed in advance properly of the intention of those NGOs that wish to participate to such technical meetings and on how these NGOs plan to contribute to the technical work at hand. This violation of non objection principles has the potential to transform a technical and inclusive process into a politically charged one and may deter constructive engagement. We call for transparency and respect for the concerns of all Member States when determining NGO participation and reiterate our support for applying either the criteria in ECOSOC Resolution 199631 or the non objection principle as safeguards.

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

Thank you.

The Committee has just concluded this stage of its consideration of Agenda Item 3.

The Committee will resume its consideration of Agenda Item 4, entitled Framework Convention Protocol 1 on Taxation of Income Derived from from the Provision of Cross Border Services in an Increasingly Digitalized and Globalized economy and the Protocol to Armed Prevention and Resolution of Tax Disputes. Of Tax Disputes I now open the floor for general statements by delegations. Please press the microphone button if you wish to speak. Delegations wishing to speak on behalf of groups are requested to approach the Secretariat to be given priority as announced in the Journal. Time limits are four minutes for statements on behalf of groups and three minutes for statements in national capacity.

I now give the floor To His Excellency Mr. Grace Wilkin, Attorney General and Minister of justice and the Legal affairs of St. Kitts and Neves, speaking on behalf of caricom.

Thank you, Chair. Distinguished Delegates, I have the honor to deliver this statement on behalf of the 14 member states of the Caribbean Community. CARICOM. CARICOM warmly welcomes the establishment of the Intergovernmental Committee pursuant to General Assembly Resolution 79235 which recognize the urgent need to develop a truly inclusive and effective framework for international tax cooperation. For too long, small island developing States and other developing countries have been marginalized in global tax governance operating within systems that inadequately address our unique challenges and development needs.

The current international tax architecture presents significant barriers to CARICOM Member States in their pursuit of sustainable development, particularly in the taxation of cross border services and the resolution of tax disputes. As highlighted in work stream discussions, many CARICOM countries depend on gross basis withholding taxes as a practical means of taxing non resident service providers. Due to limited administrative capacities. However, this approach is often hindered by restrictive bilateral tax treaties that prevent the implementation of preferred taxation methods. As a result, our Member States are subjected to an inequitable system in which complex transfer pricing rules better suited to residence based taxation models in developed economies place undue strain on already limited resources.

This is why CARICOM believes the Framework Convention we craft must be anchored in the principle that efforts in international tax cooperation should be universal in approach and scope and should fully take into account the different needs and capacities of all countries as stated in the Addis Ababa Action Agenda on Financing for Development. For caricom, this means ensuring that the Framework Convention provides practical solutions to our revenue mobilization challenges while respecting our sovereign right to design tax systems appropriate to our circumstances. The Framework Convention must facilitate, not hinder, our efforts to achieve the sustainable development Development goals. Thank you, Chair.

Thank you.

Distinguished Delegate of Ghana, on behalf of the African Group.

Thank you, Chair. I have the honor to speak on behalf of the African Group. Chair, Excellencies, Distinguished Delegates, Let me begin by extending our warmest congratulations to the newly elected Member of the Bureau. We also take this opportunity to express our sincere gratitude to you Chair, as well as the CO leads of the various work streams, all members of the Bureau and the Secretariat for the exceptional work you have undertaken during the intercessional period. The Africa Group recognizes the significant effort invested in the preparation preparation of the detailed issue notes and the thoughtful facilitation of consultations.

We are also thankful for the insightful written contributions from Member States which form the foundation upon which our deliberations for this session will build. Chair we gather here at a truly historic juncture not only for the Global south, but for every nation that has long been denied an equitable seat at the international tax table. This is not just another meeting. It is the first time in history that the global community, under the auspices of the United nations, is coming together to design a new International Framework Convention on Tax Cooperation, one that is inclusive, one that is just and one that is driven by shared principles rather than power asymmetries. The recent announcement by the G7 to exempt some countries from their commitments under Pillar 2 serves as a policy powerful reminder of the broken nature of the current tax architecture.

It highlights a truth many of us have long that the status quo is not only inadequate, it is unfair. The current system, driven by club based arrangements, continues to marginalize the voices of the many in favor of the few. It is precisely because of such development that this process, this United Nations Framework Convention, must succeed. The African Group comes to this session with hope, determination and a deep sense of responsibility. We are not here to replicate old structures or reinforce existing imbalances.

We are here to co create something new, a system that works for all, a framework that levels the playing field, a convention rooted in equity, transparency and the sovereign right of every nation to raise revenue justly from the economic activity that occurs within its borders. Excellencies, distinguished delegates, allow me now to share some of the Group's priorities across the various work streams. On Work Stream 1, the African Group emphasizes the need to expand the commitments outlined in paragraph 10 of the Terms of Reference to include critical issues such as the taxation of income from natural resource extraction. Additionally, the Group highlights the importance of of prioritizing the development of the Convention structural and governance elements such as the Conference of the Parties, the Secretariat and Subsidiary bodies, given their foundational role and the need for sufficient time to fully elaborate them. Regarding Workstream 2, the group emphasizes that the Protocol should be future proof by covering a wide range of services, including digital and emerging ones, uphold the principle of taxing where economic activity and value creation occur, follow simple and administrable rules and include a multilateral solution to overcome limitations imposed by existing tax treaties.

The Africa group's position on Workstream 3 emphasizes the urgent need to address cross border tax disputes in a globalized economy that often disadvantages countries with limited access to mechanisms like mutual agreement procedures and arbitration. The Group calls for a fair, accessible and balanced dispute resolution framework that avoids replicating inequities of investor state arbitration. It supports optional mechanisms with strong safeguards and technical support, including joint audits, capacity sensitive APAs and regionally adaptable compliance models. Chair Distinguished Delegates, Before I conclude, allow me to raise a matter of institutional importance. It has now been eight months since the adoption of Resolution 79, 235, and yet the implementation of some of its core elements, particularly operational paragraph 12 relating to the provision of the necessary facilities and resources, including a technical Secretariat to support the work of the Committee has proceeded at an unacceptably slow pace.

The African Group acknowledges the serious liquidity constraints currently confronting the United Nations. However, we must be clear this process, the development of a United Nations Framework Convention on International Tax Cooperation, must be treated as a priority. It is not simply a technical exercise. It is a transformative opportunity to correct systemic imbalances in the global tax system and to place the United nations at the heart of a global economic governance where it rightfully belongs. The credibility of this process depends on timely institutional support and adequate resourcing.

We therefore urge the Secretariat and the wider United nations system to take all necessary steps to accelerate implementation and ensure this effort receives the backing it deserves. We have before us a unique opportunity to craft a framework that will shape global task cooperation for generations. And while the road ahead may not be easy, we are encouraged by the spirit of engagement, mutual respect and shared purpose that this process has fostered so far. The Africa Group believes that this process belongs to all of us. It is inclusive, it is transparent, and it must remain grounded in the fundamental principle of equality among nations.

We thank all delegations for their continued engagement and we call on each and every one of you to bring your best ideas, your boldest thinking and your deepest commitment to justice to the table. I thank you very much.

Thank you, Distinguished Delegate of Denmark, on behalf of the European Union.

Thank you, Chair, Distinguished Delegates, Colleagues, I have the honor to speak on behalf of the 27 member states of the European Union. We, the Member States of the European Union, are here to continue the negotiations on the future United Nations Framework Convention on International Tax Cooperation and its two early protocols in a constructive and inclusive manner. For us, this process represents a good opportunity to consider current tax related challenges and to contribute to enhanced tax cooperation at international level. We acknowledge the principles on which the future Framework Convention and its protocols are to be built. All tax policies should encompass general principles of equity, transparency, efficiency, legitimacy and certainty, while recognizing that every Member State has a sovereign right to decide on its tax rules.

In this regard, our shared objective is to promote the stability and coherence of the international tax architecture. We are willing to engage in exploring ways to strengthen international tax cooperation frameworks for them to better reflect the diverse needs, priorities and capabilities all countries Ahead of this Session A lot of work has already been conducted in three work streams, yet a lot of work remains to be done. We would like to thank you, Mr. Chair, for taking the leadership in this process. We would also like to express our gratitude to the co leads of all three work streams.

The discussions in each work stream have created a forum for sharing ideas and expertise and at the same time leaving room for expressing perspectives and concerns. Nonetheless, we consider that more in depth analysis would have been necessary to enable the Issue Notes to provide a more balanced overview of the issues which are to be addressed in the Framework Convention and its two early protocols. In this way, more meaningful engagement could have been encouraged among the Member States. That being said, we do highly commend all participating Member States for their contributions and for advancing the work in a collaborative way. We also extend our appreciation to the Secretariat for its work in preparing the documents for these sessions.

In this context, we would like to reiterate that timely and transparent preparation of documents play a crucial role in supporting a truly inclusive and effective process. It also helps improving the quality of our discussions as it allows all parties to prepare and participate on an equal footing. Talking about participation we are of the opinion that EU representatives should be allowed to participate in the informal meetings of the work streams. The rules and long established practices of the UN General assembly should be followed without exception. Inclusivity is at the core of this process and we strongly believe that a more inclusive participation in the informal work streams could have a positive effect on the final output.

Building on a diverse range of of expertise as we move into the formal and detailed negotiations, we, the Member States of the European Union, remain willing to engage in a pragmatic, inclusive and forward looking manner. In this spirit, we are ready to contribute constructively to the discussions. We believe that these sessions should be used to further analyze the identified issues, also considering economic evidence and define areas of convergence to support the substantial development of the future Framework Convention and its two early protocols. As we have consistently underlined, our objective should be to reach agreement by consensus and to maximize synergies with existing international standards, with a view to avoiding any duplication of work or efforts. In this regard, we will engage in working towards a framework Convention which entails high level commitments which are not self executing.

A first early protocol which relies on a thorough analysis and fully reflects the extended efforts already made in other international fora to address tax challenges arising from the digitalization of the economy and a second early protocol which builds on the existing legal frameworks for dispute resolution and and Prevention. Mr. Chair, distinguished delegates, colleagues. We, the Member States of the European Union, are looking forward to participating in these sessions and to working with you towards to towards a successful and substantive outcome. Thank you.

Thank you. Distinguished delegate of Brazil,

Mr. Chair, Excellencies, Distinguished Delegates. Brazil is honored to address this first session of the Intergovernmental Negotiating Committee on the UN Framework Convention on International Tax Cooperation. This Convention represents a historic opportunity to correct imbalances in global economic governance and ensure all countries shape international tax standards equally.

A universal, inclusive and development oriented approach is essential. In our view, the Convention must support developing countries in tackling these urgent limited institutional capacity, inefficient and regressive tax systems, fiscal constraints and persistent asymmetries that hinder growth and resource mobilization. These imbalances are evident in restrictions on source based taxation, unbalanced distribution of taxing rights and chronic revenue losses for net importers of capital, technology and services. True international tax cooperation must advance fiscal justice and sovereignty. All countries should be able to tax economic activity within their markets or with a relevant nexus with their jurisdictions.

The Convention must help modernize tax systems, enhance transparency and ensure equitable allocation of taxing rights. Simplicity, effectiveness and flexibility are critical. The Convention must deliver for all countries, not just in commitments, but in swift implementation. Supporting capacity building in developing countries for domestic resource mobilization and expansion of fiscal space to finance the Sustainable Development Goals, particularly hunger and poverty eradication. Brazil endorses the principles of inclusiveness, progressiveness and policy space as affirmed during our G20 presidency.

These must guide efforts to build fairer development oriented tax systems that reduce inequality and drive economic transformation. We look forward to constructive negotiations committed to consensus based outcomes that are sound, feasible and responsive to the Global South. Thank you.

Thank you. Distinguish Delegate of Netherlands followed by Linkstein.

Thank you, Chair. We align ourselves with the statement made by Denmark on behalf of the European Union Member States and in our national capacity, we wish to make the following additional remarks. The Kingdom of the Netherlands reiterates its full support for efforts aimed at promoting inclusive, effective and and fair international tax cooperation. We would also like to express our gratitude to you, Chair, and to the CO Leads and to the Secretariat for their invaluable work in facilitating these discussions and preparing the issue notes. We also believe it is important to remember that this process consists of three distinct phases.

First, this Committee will decide on the drafting of the Framework Convention. Second, it is then every Member States own prerogative to sign on to the Convention. Third, and finally, while the commitment to the Convention is already a significant step, Member States will also retain the freedom to decide whether to sign on to specific operative protocols under the Convention. A successful outcome will be achieved when both the Framework Convention and its Protocols are drafted in a manner that garners the broadest possible support. Trying to find consensus is therefore in the primary interest of all of us.

Allow me to reassure you the Kingdom of the Netherlands active and constructive participation throughout this process. Thank you.

Thank you, Distinguished Delegate of Lingestein, followed by India Chair, Excellencies, Distinguished Delegates, Liechtenstein thanks the Secretariat and the CO leads for their work over the past few months. We appreciate the constructive dialogue among the Member States and the input from various stakeholders, as well as the opportunity to contribute further to the development of the Framework Convention and its Protocols. As this work progresses, it is important that the Convention, to serve as a framework, remains broad and flexible in its design. To ensure the widest possible acceptance and to remain future proof, we believe it is essential to keep the commitments stated in the Convention at a high level and not self executing, while leaving the scope and technical details to the respective Protocols. This issue was discussed during the development of the Terms of Reference, and we believe it remains key to securing the participation of as many jurisdictions as possible.

Additionally, we would like to draw attention to the fact that overly strong and detailed commitments in the Framework Convention could undermine the optionality of the Protocols. Commitments should not go beyond what is outlined in the Terms of Reference, and it is worth recalling that even those commitments have raised concerns regarding optionality. In our view, the Framework Convention should function as an overarching frame framework, with further obligations to be developed and agreed upon through separate protocols. Furthermore, we believe that the more comprehensive scoping exercise could help to more specifically identify areas where the Framework Convention provides added value and avoid unnecessary overlap with existing standards and work carried out in other international forums. We see merit in conducting a more thorough analysis of the current landscape, including the existing needs and economic impact of the envisaged measures regarding the Protocols, particularly the first Protocol.

It would be useful to consider existing work to a larger extent. Thank you for taking our considerations into account for the upcoming work, and we look forward to constructive discussions during this session. Thank you.

Thank you, Distinguished Delegate of India, followed by Algeria.

Thank you, Chair Excellencies distinguished delegates, we have indeed come a long way since the adoption of Resolution 78230 would set us on this path towards seeking an equitable solution to the challenges of international tax cooperation. From that moment on, we embarked on a journey that that required resolve, mutual trust and a shared vision. Over the past several months, we have engaged fruitfully in developing the Terms of Reference and advancing the work of the Intergovernmental Committee. Now, more recently, we have witnessed constructive discussions on the development of the Framework Convention and early Protocols through the work streams.

These efforts have shown that when guided by collective purpose, progress is not only possible, it is inevitable. This is demonstrated by the progress and the work done in the three work streams in a very short period of time. Today, as we gather for this first substantive session, we must reaffirm our commitment to ensuring that the objectives and principles we have endorsed begin to take shape in a way that reflects our voice, our aspirations and our common understanding. FAIRNESS when we began this journey, there were understandable doubts about whether consensus on such a complex subject could be achieved. Taxation is inherently challenging and the diversity of our perspectives, sometimes divergent, makes agreement a formidable prospect.

Yet we have demonstrated that it is possible to build consensus and agreement on issues of real significance. This achievement stands as a testament to the spirit of cooperation that has united us. India believes that our foremost objective must be to establish a Framework Convention of the highest quality. Its strength and credibility will bind Member States to its provisions in both letter and spirit. The commitments we enshrine must provide clarity and direction not only to the early protocols, but also to those that we will negotiate in the future.

We also believe that the commitments should move beyond the broad formulations of the Terms of Reference, striking a balance between remaining high level and offering enough detail to guide meaningful implementation. As we proceed, it is vital that we agree on the form and process that will sustain the transparency and trust that we have built. India assures all Member States that we will engage constructively and contribute our technical expertise and every effort necessary to build a framework that benefits our governments, our citizens and our businesses alike. Let us remain guided by the conviction that an equitable international tax system is essential for sustainable development and a fairer global economy. Together, we will surely achieve this goal.

Thank you.

Thank you, Distinguished delegate of Algeria, followed by Italy.

Thank you, Mr. Chair. Mr. Chair. Distinguished delegates, I wish to extend my sincere appreciation to the Chair, the members of the Bureau and the Secretariat for their continued commitment and the quality of the work accomplished.

Algeria aligns itself with the statement delivered by the African group and would like to add the following in its national capacity. Mr. Chair, Algeria expressed its support and commitment to the work of the Intergovernmental Negotiating Group on the United Nations Framework Convention on International Tax Cooperation and its two protocols, which constitute an important stake step towards reshaping the architecture of the international tax system to make it more inclusive, fair, transparent, efficient, equitable and truly contributing to sustainable development. While respecting the sovereignty of Member States and taking into account the needs and priorities of developing countries, the system will be able to increase the legitimacy, legal certainty and fairness of of international tax rules and will strengthen the fight against tax fraud and evasion and illicit financial flaws. We also applaud the methodical approach that made it possible to identify priority thematic areas, to address them within three work streams and to produce high quality thematics notes which faithfully reflect the in depth discussions held within these work streams and which also constitute a valuable basis for guiding our debates, promoting a common understanding of the challenges ahead and progressing towards concrete and balanced results.

Algeria subscribes to the positions expressed by the African Group, particularly in regard to the need to formulate commitment in sufficiently large scope to allow for a certainty, flexibility and adaptability to future circumstances across border services play nowadays a very important role in the economy. We underscore the importance of ensuring a fairer distribution of taxing rights between the state of source and residents. In this context, the Framework Convention and its protocols must take into account the difficulties of encountered by States and provide effective, simple and quick implementation mechanisms in order to correct the imbalances currently found in existing bilateral tax treaties. Therefore, the adoption of simple and effective rules that allow for a fair distribution of taxing right is necessary in order to enable source countries as well as countries of residence to guarantee a broader tax coverage adapted to the diversity of economic models.

The new Sorry this new approach will reconcile the requirement of tax justice, administrative efficiency and international coherence while protecting the legitimate right of market jurisdiction in a rapidly expanding digital environment. Furthermore, and taking into account the increasing global economic exchanges which give rise to international tax dispute, Algeria support that the UN Framework Convention on International Tax Cooperation should prioritize dispute prevention through clearer rules, tax cooperation and transparent multilateral dialogue. While emphasizing the importance of administrative assistance, we also wish to emphasize that capacity building remains a priority, particularly for developing countries to participate fully in international tax cooperation and effectively implement the Framework Convention and its protocols. To conclude, Algeria remain fully committed to constructively contribute to the effort undertaken to develop the Framework Convention and its two protocols.

Thank you, thank you, thank you of Italy, followed by Kenya, then Russia

thank you, Chair.

Italy aligns with the statement delivered by EU Danish Presidency on behalf of the 27 EU Member States and would like to add the following remaining remarks on national capacity. We would like to express full appreciation for the work done by the Chair, the Secretariat and the co leads of the three work streams. Italy recognizes that the UN Framework Convention represents an important opportunity to contribute establish an inclusive and effective international tax cooperation framework. In that respect, we would like to reiterate our request to build on existing achievement in the area of international tax cooperation and taking into account the previous works when exploring technical solutions, in particular with the Protocols. This approach would maximise the efficiency of our negotiations and pave the way for more robust and stable outcomes.

Being aware that participating countries might have different priorities, Italy would like to underline that any durable outcome could only be reached to the extent it is successfully implemented by a broad range of countries. In this perspective, despite the hybrid decision making rule defined in February, Italy would like to stay stress again that it is essential to work with the aim to reach consensual solutions. Otherwise, the outcome of the negotiations may face significant challenges in gaining widespread implementation. With a view to set a new forward looking international tax Convention. The intergovernmental negotiating commitment should ensure that the new legal instruments are well anchored in principles.

Stability, administrability and certainty would be the basis of the Framework Convention and its Protocol. With regard to the Framework Convention principles should be translated into high level commitment, so to design an overarching legal architecture to be further developed and implemented through the different protocols. In our opinion, the Protocol also need to be rooted in well established and shared principles. The negotiation to develop the legal instruments should be grounded in analysis with the aim to evaluate their benefits for investment, trade and growth. Moreover, any technical solution should not dismiss the taxpayer's rights.

The Framework Convention and the Protocols can contribute enhance domestic resource mobilization which is essential to support the sustainable development. However, we are strongly convinced that improvement of domestic resource mobilization can only be achieved through legal instruments. But it requires also other means, including mechanism that strengthen capacity building. As we move towards this week of negotiations, Italy remains constructively engaged in good faith negotiation. Thank you, Mr.

Chair.

Thank you, Distinguished delegate of Kenya, followed by Russia in Spain.

Thank you, Chair, Excellencies, distinguished delegates. At the onset, Kenya aligns itself with a statement made by Ghana on behalf of behalf of the Africa Group and wishes to make the following statement in its national capacity. Mr. Chair, Kenya approaches this first session of the Intergovernmental Negotiating Committee with a deep sense of responsibility and optimism. This process represents the first truly inclusive effort under the auspices of the United nations to design a global framework for international tax cooperation.

It offers a historic opportunity to address long standing iniquities in the current tax architecture and to ensure that the voices of developing countries are fully reflected in the outcome. Mr. Chair, the current international tax system remains characterized by fragmented arrangements that often leave developing countries on the margins of decision making. These imbalances have significant implications for our ability to mobilize domestic responsibility resources, finance sustainable development and respond effectively to global challenges. A multilateral framework anchored in the UN is therefore essential to achieving fairness, predictability and legitimacy in global tax cooperation.

Mr. Chair, Kenya's priorities for this session are threefold. First, we underscore the need for the Framework Convention to enshrine equity as a guiding principle. This includes a fair allocation of taxing rights, recognition of the diverse capacities of Member States and provisions that enable countries to benefit from economic activity occurring within their borders. Second, we support the early establishment of clear institutional arrangements, including a Conference of the Parties, Secretariat and Subsidiary Bodies, to ensure that the Convention can function effectively from the outset.

These structures must reflect equitable geographical representation and be adequately resourced. Third, on the substantive commitments, Kenya calls for comprehensive coverage of key issues such as digital and emerging services, taxation of natural resources and robust mechanisms for the prevention and resolution of tax tax disputes. Such mechanisms must be fair, accessible to all Member States and avoid replicating inequities found in existing dispute resolution systems. Mr. Chair, Kenya remains mindful of the financial and procedural challenges confronting this process, including the need for timely technical support and adequate resources.

We urge the Secretariat and Member States to prioritize the implementation of Resolution 79, 235 to maintain momentum and credibility. In conclusion, Kenya stands ready to engage constructively with all delegations in the spirit of transparency and inclusivity. We are committed to contributing to an outcome that reflects the aspirations of all Member States and lays the foundations for a just and development oriented global tax framework. I thank you.

Thank you. Thank you. Russia, followed by Spain, then Korea.

Distinguished Chairman, good morning to all of the participants in the first session of the Negotiating Committee. We express our gratitude to the Secretariat and the members of the Working Groups for the work that they done to prepare the issue notes for this session. This week, the Committee will discuss the issue note on the development of the Framework Convention. The Russian Federation sees the Convention as the fundamental global instrument that is needed in order to affirm the principles upon which international tax cooperation in the interests of all States will be built. We're of the view that commitments under the Convention need to be formulated as broadly as possible so as to as much as possible cover the stated goals and targets to create a governance system in the area of international tax cooperation, one that will be able to respond to existing and future tax challenges.

The Convention will form a basis for the development of the two early Protocols as well as all of the subsequent ones. And in that regard, given the optional nature of the Protocols, we call for the Convention's commitments to be drafted such that they establish the fundamental principles and approaches to addressing issues and to constitute an independent set of rules. Regardless of the Protocols, we believe it is important to try to create a global instrument that would have practical import when it comes to addressing existing tax problems, rather than one that is simply declaratory in nature. At the same time, we are confident that the effective implementation of the provisions of the future Convention is not possible without transparency, and that can be achieved through the effective exchange of information. And in that regard, we propose including provisions on the exchange of information in the commitments under the Convention.

In conclusion, we would like to note that Russia is actively participating in all of the areas of the Committee's work. We are convinced that the Convention and its two early protocols will help increase tax certainty and defend and grow the tax base at the national level. In turn, additional tax revenues will allow developing countries to boost investments in sustainable development and to reduce their dependence on external sources of financing. We call on everyone to join forces to build a fair and effective international tax system that meets the challenges of the 21st century. Thank you very much.

Thank you, Distinguished Delegate of Spain, followed by Korea and Hungary.

Distinguished Chairman, distinguished delegates, it's an honour to address you on behalf of the Spanish delegation. We align ourselves with a statement by Denmark on behalf of all of the Member States of the European Union. We consider that this process offers an excellent opportunity to consider current tax challenges and to contribute to the strengthening of international cooperation in this area. We understand that any tax policy has to be based on the values of equity, transparency, efficiency, legitimacy and legal certainty, without forgetting the principle of tax sovereignty that each State has. We share the goal of promoting stability and the consistency of the international tax framework so that it better reflects the different needs, priorities and capacities of all countries.

And we would like to thank you, Mr. Chair, as well as the CO leaders of V3 work stream, for their work and their dedication during this period. We also very much appreciate the contributions of all of the countries involved and we recognise the progress that has been achieved by working together. We also thank the Secretariat for preparing the working documents, reiterating that the timely and transparent production of those documents is essential to guarantee a truly inclusive and efficient process. We reaffirm our readiness to work together in a pragmatic, inclusive and future oriented mindset and to contribute constructively to the debates.

And as we have said from the outset, our goal is to achieve agreements by consensus in line with existing international standards and thus avoiding unnecessary duplications. In this context, we will work for a framework Convention that contains just general and non binding commitments, a first protocol based on a rigorous analysis and that fully reflects progress made in international fora when it comes to tax challenges relating to the digital economy and a second protocol that makes the most of the existing legal frameworks on dispute prevention and resolution. Moreover, we support the commitment to align international tax coordination cooperation with sustainable development, taking into account what was agreed by consensus in the Sebiyeh Commitment a few days ago as relates to progressive taxation to reduce inequalities, including the effective taxation of high net worth individuals, the environment, gender and human rights.

We most certainly look forward to actively participating in these meetings and we look forward to working with you all to achieve a successful outcome. Thank you very much.

Thank you, Distinguish Delegate of Korea followed by Hungary and Indonesia.

Thank you. Chair I would like to express my appreciation to all Member States and the Secretariat for their work in support of the discussion on the Framework Convention and the two Protocols. I especially value the efforts made to reconcile diverse views and deliver meaningful outcome despite a tight schedule. I believe that this collective effort will serve as an important foundation for advancing the future framework of international tax cooperation. Before we proceed, I would like to highlight three key points.

First, with respect to the fair allocation of tax, Singh writes, I recognize the limitations of existing tax rules which are based on fiscal presence, and the need for new rules in light of the changing business models brought by the digital economy. However, given the complexity of setting standards for allocating taxing rights and the lack of agreement among jurisdictions on how fairness should be defined, I consider it appropriate that the relevant provisions in the Framework Convention be drafted at a high level. Second, regarding the effective prevention and resolution of tax disputes, I recognize the importance of this issue given its role in ensuring the elimination of double taxation for taxpayers and in improving administrative efficiency and effective use of resources resources for tax administrations. That said, I believe that the Framework Convention should focus on setting out the overall objectives and directions for tax dispute resolution, while the detailed procedures and mechanisms would be most effectively addressed within the protocols. Third, concerning the sustainable development, I recognize the importance of achieving balanced social, economic and environmental progress.

Having that said, I believe it is important to more clearly highlight why this topic should be addressed within the framework of international text discussions and to better articulate the rationale for cooperation among jurisdictions in this context. In addition, for the commitment not addressed during this session, I believe it is important to ensure broad consultation with Member States and to build common agreement under the shared objective of promoting inclusive and effective international tax cooperations. In closing, I hope that discussions ahead will produce constructive outcomes grounded in mutual trust and cooperation among Member States. Thank you.

Thank you, Distinguished delegate of Hungary, followed by Indonesia and China.

Thank you, Mr. Chair, dear chair, distinguished delegates and colleagues, Hungary fully aligns with and supports the statement delivered by the Danish delegation on behalf of the 27 member seats of of the European Union and we would like to add in our national capacity the followings. Hungary underscores the importance of inclusive, effective and fair international tax cooperation. Hungary also affirms the core principles of equity, transparency and efficiency, legitimacy and uncertainty in tax policy, while fully recognizing the sovereign right of all states to determine their own tax systems. In this period, we remain actively engaged in the negotiations and the future United Nations Framework Convention and the two early protocols.

Hungary appreciates that the United Nations Framework Convention provides a valuable forum for global dialogue and we support exploration of opportunities to create policy synergies wherever possible. While we acknowledge the diverse needs, priorities and resources of all countries, at the same time we emphasize the importance of avoiding duplication of work. It is essential that that the United Nations Framework Convention complements rather than undermines existing international instruments. Significant work has been undertaken and notable achievements were made in other international fora which should be duly taken into account. The work and the United Nations Framework Convention should also seek to reach agreement by consensus in line with established practices in other international fora.

Regarding the conduct of technical work, we highlight the need for in depth technical analysis and impact assessment. Also of all proposals, clear and transparent procedural guidelines, timely scheduling of meetings and the prompt preparation and distribution of documents are all critical for enhancing the efficiency efficiency of the negotiations and both during and between the sessions and also to foster the development of high quality and long term solutions. With this in mind, we really appreciate the preparatory efforts of the Chair and the Secretariat for this session and we look forward to continuing our constructive engagement towards successful outcome. Outcome thank you very much.

Thank you. Thanks. Delegate of Indonesia, followed by China and United Arab Emirates.

Thank you, Chair. Indonesia welcomes this substantive session as a pivotal step toward building a just and inclusive international tax system in a global economy increasingly shaped by digitalization and globalization. Developing Countries risk further being left behind not only in innovation, but in taxation. More and more economic value is now created and consumed remotely through digital platforms, automated services and user participation across borders. Yet existing provisions remain greatly anchored in physical presence, leaving jurisdictions, especially in the Global south, without a fair share of taxing rights.

This is a serious wake up call that if unaddressed, the erosion of source based taxation will widen inequality, weaken countries capacity and constrain fiscal space for sustainable development. In this connection, we wish to reaffirm that the establishment of the Framework Convention shall set high level principles and safeguards while placing technical details in protocols to allow flexibility, adaptability and phase implementation. The Convention and its protocols must ensure countries, particularly the developing ones, can tax income from digital markets and services regardless of physical presence. Against this backdrop allow us to highlight three key issues for us to move forward. First, capacity and fairness.

We must address asymmetries between tax administrations. Let's equip countries with tools, not just rules, which consequently urges robust technical assistance, capacity building and dispute management training. We also share the importance of critically reassess the idea of the use of mandatory binding arbitration in tax cases. Such clauses warrant heightened caution given capacity gaps, cost and sovereignty concerns. Second, sovereignty.

Multilateral commitments must protect, not shrink, domestic policy space. The Convention should not intrude into purely domestic tax disputes. Jurisdictions must also be able to tailor administration to local realities while adhering to agreed minimums. Market jurisdictions must retain rights to tax income tied to real economic activities, including significant economic presence without physical operations. Value creation should guide but not solely determine taxing rights.

Demand side contributions matter. Third, equity and inclusivity. Equal participation is essential. The system must address, not entrench existing asymmetries. Key guiding principles are critical including efficiency, neutrality, simplicity and administrability to reduce disputes, compliance burdens and and opportunities for base erosion and profit shifting.

This work should align with the SDGs by safeguarding revenues, reducing inequality and strengthening state capacity. In closing, the Framework Convention should halt the erosion of source based taxation, reflect modern business realities and equip countries to collect what is rightfully theirs. Let us build a system that is fair, future ready and founded on trust. Thank you, thank you. Distinguish Delegate of China, followed by United Arab Emirates and Turkey.

First, I would like to thank Mr. Chair and the Secretary for the great efforts and leadership during the process and the participation and efforts from other Member States as well. And I will present our General statement in Chinese. So please put on the earphone.

Distinguished Chair Dear Delegates, we have always supported the UN in playing active role in the formulation of International Tax Rules and International Tax Coordination we welcome and support the efforts made by the UN to promote inclusive and effective international tax cooperation. During the Convention negotiations, Member States have identified the current priorities including taxation of the cross border service income, prevention and resolution of tax disputes, among others. We believe that all countries should strive to develop an inclusive and a balanced global convention. In current negotiations and future discussions, the positions of countries at different stages development should be fully considered. Efforts must be made to seek convergence and bridge differences to the greatest extent through thorough discussion and broad consultation.

We support three work streams established by the INC and actively participate in the drafting of the Framework Convention and the two early Protocols. We appreciate the efforts and progress made by each work stream and will continue to contribute actively. We hope that the INC and its work streams will strengthen coordination, make sound scheduling of meetings in terms of numbers and frequency to improve negotiation efficiency. With regard to the Framework Convention, we believe that the Convention should primarily consist of high level and micro level principles and specific substantive provisions on rights and obligations be clarified in the Protocols. The Convention can promote the gradual modification improvement of international tax rules and should avoid radical changes or even disrupting existing international tax system.

Currently, the Issue Notes summarizes the consensus among countries on the Convention. Comments using high level and principle based language reflecting the discussions of the work stream 1. Rather objectively looking ahead will continue to actively participate in negotiations and formulations of the Framework Convention. Two Protocols we look forward to working with all countries to promote inclusive and effective international tax cooperation. Thank you.

Thank you. Thank you. Delegate of United Arab Emirates, followed by Turkey and cameroon.

Thank you, Mr. Chair.

We would like to express our deep appreciation to the Chair and Secretariat for their commitment and dedication in developing the United Nations Framework Convention on International Tax Cooperation. We agree with many in this room that the current international tax architecture has challenges and gaps that have contributed to global inequitable growth. We therefore recognize the critical importance of this initiative in enhancing inclusive global tax cooperation and promoting a fair and equitable global tax system. The proposed Framework has the potential to address significant challenges in international taxation and foster greater collaboration among nations. The UAE continues to actively engage on a constructive basis in all three UN work streams and will continue to use its role as a BIRU member in promoting the design of sustainable tax policies that promote equitable economic growth in areas of international taxation where gaps currently exist.

With respect to the Framework Convention itself, while we strongly support the overall project objectives, we believe the commitments of the Convention should be kept at a high level and the active consultation with all stakeholders is undertaken throughout all stages of the Convention. This ensures that the Convention remains simple and can be signed by the broadest majority of jurisdictions. We would suggest that the commitments could make reference to the topics that would be covered in the Protocols and given the technical nature of international tax, that any scoping or technical aspect are left to the Protocol themselves to address. We look forward to further discussions and refinements of this important initiative to address our concerns and strengthen international tax cooperation. Thank you, Mr.

Chair.

Thank you, Distinguished Delegate of Turkey, followed by Cameron and Ghana. Thank you, Chair, Excellencies and Distinguished Delegates. Turkey expresses appreciation to Work Stream's Colleague, Secretariat and Members for all the efforts in advancing the work and confirms its commitment to participate constructively in the discussions. Multilateralism and international cooperation are key instruments to addressing global challenges. In this perspective, Turkey recognized the opportunity to continue the discussion on how to further promote inclusive and effective international tax code cooperation.

Turkey reaffirms that national sovereignty should be respected and each country should have the right to choose their own tax policies according to their circumstances. Hence, Turkey fully supports optionality with respect to mechanisms within the Protocols rather than binding obligations, which will provide flexibility for countries with diverse legal systems and policy preferences and promote broader participation to the Protocols. Turkey SV regarding the Framework Convention is that Convention should be designed by using broad language without detail. Detailed and substantive provisions specifying rights and non binding obligations should be defined in relevant protocols. International text works already undertaken in other relevant forums.

Existing tools, strengths and expertise as stated in the terms of reference should be considered to ensure a synergistic approach to global tax challenges. It is also essential that the complementarity should be a guiding principle and protocols does not conflict with existing mechanisms. Under bilateral treaties and internationally recognized principles, Turkey will continue to engage in the discussions openly and constructively to find a common way forward at the global level. Thank you, Chair.

Thank you. Thank you, Delegate of Cameroon, followed by Ghana and Norway.

Dia Chair, Vice Chairs, distinguished Delegates, colleagues. Cameroon is honored to take the floor at this crucial moment, one that offers the world a chance to correct long standing imbalances in the global tax system. At the outset, I would like to extend my deep appreciation to you, Mr. Chair, for your continued leadership in guiding the work of this Committee, as well as my gratitude to the Bureau Members, the Secretariat of the UN and to all delegations whose relentless work has made this process possible. Cameroon aligns itself with the statement delivered on behalf of the African Group, while adding the following comments in its national capacity.

Mr. Chair, this is not merely a negotiation for Cameroon and for many nations in the Global South. It is a matter of urgent economic necessity and national sovereignty. For too long, the global tax system has been failing to reflect the unique challenges and priorities of developing countries like ours. The absence of a strong, unified framework costs our nation vital resources that are essential for funding our schools, our hospitals and infrastructure.

Cameroon's prosperity and our ability to achieve sustainability and sustainable development goals is directly tied to the success of this convention. We need a framework that corrects these imbalances and provides a clear, efficient path to a fairer distribution of tax revenues. Therefore, we stand in support of a framework convention on International Tax cooperation and we call for a rapid conclusion of these negotiations. The urgency of this task cannot be overstated. Each day of delay means further erosion of our tax basis and a continued drain of our national treasuries.

The time for a new convention is now. Mr. Chair. The effectiveness of this convention will will be measured by how boldly and quickly we address the inequalities that undermine sustainable development. The Convention must not only be a tool for transformation in theory, but must be a practical instrument that offers tangible benefits.

For Cameroon, this means a framework that recognizes our diverse tax systems while providing immediate commitments to to capacity building, technical support and truly equitable representation in all governance structures. Mr. Chair, let us choose cooperation over competition, fairness over unilateralism and equity over exclusion. Let's make every voice matter and let's act with the small speed and purpose that this historic moment demands. Cameroon stands ready to work with all member states to create a convention that is not only coherent and transparent, but one that strengthens global tax governance, closes loopholes and most importantly, channels resources towards the development goals that we all share.

In this vein, Cameroon ratifies its active contribution and unwavering commitment to the principles of equity, inclusivity, transparency and efficiency. Together, let us deliver a convention that will echo as a victory for fairness, solidarity and most critically, for the sustainable and urgent development of our nations across the globe. Let history remember that in this room we did not settle for status quo. We changed the course together. Thank you.

Thank you. I'm giving the floor to the distinguished representative of Ghana to continue his previous statement, followed by Norway and Switzerland.

Mr. Chair. Excuse me, Mr. Chair. Distinct Excellencies and distinguished delegates.

To begin, Ghana aligns herself with the statement delivered on behalf of the Africa Group and in making our national statement, we begin by extending warm congratulations to the newly elected members of the Bureau. We further wish to express sincere appreciation to you, Mr. Chair, Chair, to the CO leads of the various work streams and to all members of the Bureau for the clarity, commitment and collegiality that have marked the intersectional discussions, we further commend the Secretariat for the technical rigor and dedication with which they have supported the work. The documents and analysis provided have been instrumental in shaping the substance of the deliberations, excellencies and distinguished delegates. This is a defining moment for the Global south and for every member state that has felt sidelined, unheard or constrained by a global tax system built in a different era by a different set of voices.

The establishment of this intergovernmental negotiating committee signals a unique opportunity for truly universal cooperation in international tax matters, where all nations, regardless of size or economic power, can contribute equally to shaping the rules that govern us all. Just weeks ago witnessed an announcement by the G7 leaders to exempt certain countries from pillar two commitments. That decision made outside any inclusive multilateral framework serves as a stark reminder and cements our assertion that the current global tax architecture is not only fragmented, it is virtually defunct. It privileges the few, disenfranchises, franchises the many, and perpetuates asymmetries that undermine trust in the international tax system. This is precisely why the development of a UN Framework Convention is not just timely, it is necessary.

It is our collective response to a system that has for far too long failed to meet the standards of fairness, transparency and equity. Mr. Chair, Ghana fully aligns itself with the priorities outlined by the Chair of the Africa Group, and we commend the clarity and ambition embedded in the Group's positions. We will offer further elaboration on national capacity during the substantive discussions. We commend the spirit of cooperation shown by all delegations thus far.

Yet we must also express our concern. To date, no delegation from the Global north has volunteered to co lead work streams one and two. We respectively call on our colleagues from all regions to step forward and co lead. This process was built built on the principles of inclusivity, transparency and shared ownership. It is in that same spirit that we must proceed.

Before concluding, allow us to echo a point raised by the Chair of the Africa Group. It has now been eight months since the adoption of Resolution 79235 and yet progress on critical implementation tasks, most notably the recruitment of tax experts to support the schedule, remains painfully slow. We recognize the fiscal constraints facing the United Nations. Nevertheless, this process must be prioritized. Your Excellencies and distinguished Galilees.

This Convention is not merely about raising tax revenue. It is about fairness, justice and global economic sovereignty. It is about restoring trust in multilateralism and empowering nations to reclaim the revenues needed to fund their development, including the provision of basic education and health care. Ghana stands ready to work with all delegations to deliver a convention that is bold in vision, fair in substance and transformative in impact. A convention we can all own.

Mr. Chairman, I want to re echo our earlier sentiments that posterity is watching us. It will not forgive us if we do not work together to develop an international tax order that meets the needs of all. So let us work forward together with resolve, with purpose and with the conviction that this process, if done right, can help bend the arc of global economic governance towards justice for all. Thank you.

Thank you. Stanj, Delegate of Norway, followed by Switzerland and Tanzania.

Thank you, Chair, and warmly and welcome back to Turtle Bay. Distinguished colleagues and friends. Norway is committed to advancing global tax cooperation and values. The UN's role in in ensuring inclusive discussions on these matters. A fair, transparent and effective international tax system is critical for achieving the Sustainable Development Goals.

All countries, regardless of income level, must be able to mobilize domestic resources to reduce inequality and promote sustainable growth. Tackling tax evasion and avoidance, which disproportionately affect developing countries, requires strong political will and constructive engagement from all stakeholders. We should leverage the UN's convening power to forge widely supported and effective solutions in. In doing so, we can raise global ambition on tax, strengthen capacity building and ensure inclusive representation. Chair this first substantial session is a key opportunity to advance discussions and lay a strong foundation for the negotiations ahead.

Norway sees the Framework Convention as a chance to to reinforce multilateralism in tax governance. It should build on existing efforts while ensuring the voices of all are fully reflected. Inclusive cooperation means engaging all relevant actors civil society, the private sector, academia and the media. Their perspectives will strengthen our deliberations and outcomes. Norway also emphasizes the importance of complementarity with existing mechanisms such as the oecd, the Inclusive Framework and the Global Forum.

We remain firmly committed to these forums and their processes. Enhancing coordination across forums and avoiding fragmentation will improve the coherence and impact of our collective efforts. Chair we welcome the work that has been carried out under the three work streams established by the Convention process, namely the Framework Convention, the Protocol on the Taxation of Services and the Protocol on Dispute Prevention and Resolution. This work is essential in guiding our discussions and we welcome delegation's active and constructive engagement to effectively guide the process ahead and ensure the broadest possible participation. Our further deliberations should be grounded in a robust analytical framework.

We look forward to the negotiations ahead and to working with all delegations to build a robust and effective framework that benefits all. Thank you. Chair.

Thank you. Thank you. Secret of Switzerland followed by Tanzania.

Thank you, Chairman. Dear colleagues, the past years of tax work at the United nations have been an intense journey. We regret some decisions taken on the way, in particular the departure from the search for consensual solutions and from the avoidance of duplication. These may impact the acceptance of the deliverables of this committee. And we must recall that truly effective outcomes will ultimately still require a critical mass of support.

Nevertheless, we remain committed to the goals of inclusiveness and efficiency effectiveness of international cooperation in tax matters and we look forward to contributing to the work of this committee. One of our goals for the upcoming sessions is to develop a common understanding of the international taxation of income from services. Such an approach should be based on consistent principles and should require a more substantial nexus than the mere fact of a payment source in a country. The result would otherwise be a form of a tariff of the source country. And although tariffs are currently having a revival, the opinion of academia is clear and is underlined in practice by the reactions of financial markets.

Trade barriers ultimately harm all parties involved. Another of our goals is to find a solution that does not discriminate non residents with when rendering services. Non discrimination is a long standing principle of international tax cooperation and is required for business profits by both the UN and the OECD Model Tax Convention. To comply with this obligation, the tax on non resident service providers should not be higher than the tax on domestic service providers. What raises the question of the appropriate rate or basis of the tax?

Finally, our aim is to identify options for further work to strengthen dispute resolution. The mandate to develop an early protocol regarding dispute prevention and resolution implies operational changes to the current system. A party that intends to uphold its contractual commitments should not be afraid of having its interpretation of those commitments assessed by an impartial third party. Our hope is therefore to find modalities under which countries could trust a third party and would accept their findings in unresolved disputes. We look forward to productive discussions with all of you.

Thank you.

Thank you.

Followed by Republic of Iran and Chile.

Thank you. Mr. Chair. Mr. Chair.

The United Republic of Tanzania fully aligns with the statement made by the by Ghana on behalf of the African group. Mr. Chair, now I would like to make the following remarks in our national capacity. First, Mr. Chair, Tanzania firmly supports what was acknowledged in Resolution 780, 230 that all taxpayers should pay taxes where economic activity takes place, where value is created and where revenues are generated.

For countries like Tanzania, this principle is not just fair, it is vital. It allows us to Meaningfully tax cross border economic activities that are clearly benefiting from our markets. Second, Mr. Chair, we believe the Framework Convention must be a tool for global fiscal equity, broad based and inclusive. Attached in the goals of SDGs.

Tax laws must be reflecting the realities of current and future economies and they must work equally for all forms and types of businesses. Third, Mr. Chair, we can no doubt state the importance of a fair allocation of taxing rights. For us, this is not only about fairness. It is about ensuring we can raise the domestic revenue needed to meet our development goals and provide opportunities for our people.

For the Mr. Chair, this convention must respond to the urgent need to modernize outdated international tax rules. The global economy has changed, Mr. Chair. Our tax freements must keep pace.

Finally, our governance matters. Mr. Chair, for this convention to succeed, its governance structures must be inclusive. Every country must have an equal seat at the table. We must not replicate the imbalances.

We are all working to fix it. Mr. Chair, we look forward to working with all delegations to build a convention that is fair, future ready and truly global. Thank you, Mr. Chair.

Thank you. Distinguish delegate of Iran followed by Chile and the United kingdom.

Thank you, Mr. Chair. First, let me join others and thank you, the members of the Bureau and the Secretariat for all works and support. Mr. Chairman, establishing a new international tax framework is a critical process to address the imbalances and equalities that exist among us. It is imperative that the new framework upholding multilateralism and is built based on the principle of equity, inclusivity, fairness and respecting sovereignty of state, with the specific focus on the needs and interests of developing countries, including those under unilateral coercive measures.

Mr. Chairman, developing countries have historically been left behind and the global tax system excluded from key decision making forums and subjected to rules that do not align with their economic realities. This has resulted in in significant revenue losses and equality. Allow me to highlight four points. First, the new framework must prioritize a new universal and inclusive platform for tax cooperation in which United nations has its own central role where all countries have equal voices and a genuine role in shaping their rules. The new framework must address the unique challenges of countries under unilateral coercive measures.

Three, the new framework must provide robust capacity building and technical assistance for developing countries and must establish a fair and impartial system for resolving tax disputes between countries that is one that is acceptable to all countries regardless of their size or economic power. In closing, Mr. Chair, we need an inclusive process upholding multilateralism, international cooperation and reduce inequality and poverty at global level. I thank you.

Thank you. Distinguish delegate of Chile followed by United Kingdom and Saudi Arabia.

Thank you very much, Mr. Chairman. We would like to align ourselves with a statement delivered by Brazil. And we would also like to express our thanks to the Bureau for the way in which they have steered this stage of the process and the co leads of the various work streams for the thematic notes that have been put forward. And we welcome the new co chair of the Bureau. We believe that the time has come to make progress towards a substantive discussion focused on normative content of the Framework Convention.

Specifically, it will be critical for us to work on the commitments that will define its scope and effectiveness. From our point of view, this Convention should establish an architecture that makes it possible for us to respond with effective instruments to such complex challenges, such as illicit financial flows, evaluation and harmful workings to reach equitable tax cooperation. This means that we must build commitments that acknowledge the different capacities and contexts that exist in different countries, particularly in developing countries.

Chile believes it is critical that this Convention does not limit itself to general principles, but rather that it also includes operational tools that are specific in nature to bolster States tax capacities, to ensure an equitable assignation of tax rights and to contribute to the sustainable development in its three pillars.

In this regard, we think that the work should prioritise commitments that promote tax justice, transparency, the effective resolution of disputes and a human rights centered approach, with particular attention to progressivity within the tax system. One of the domains where this is particularly urgent is in the taxation of services. Traditional norms based on physical presence is increasingly insufficient given digitalized and delocalized business models. And that is why we need to move towards a common understanding of the existence of broader economic nexuses that adequately reflect the generation of value and the real contributions that are being made in different territories. We also think it is valuable for this process to make the most of the various diagnoses, tools and experiences that have been accumulated in different levels and different areas of cooperation.

This can be a foundation for us to enrich our work once again. We remain available to work constructively and we trust that the tools within the multilateral system will make it possible for us to make headway towards common solutions that will work for all. This is an historic opportunity for us to beef up international cooperation in the domain of tax and to do this in a genuinely inclusive way with the UN as a universal forum that reflects the diversity of different views and challenges that we are all facing. Thank you.

Thank you. Distinguish delegate of United Kingdom, followed by Saudi and Morocco.

Thank you, Chair and good morning everyone. The UK looks forward to continuing discussions to strengthen international tax cooperation and we thank you, the Bureau and the Work Stream leads for your work in advance of the session. We recognise many developing countries face challenges in implementing existing rules. The UK is committed to working in partnership with other jurisdictions to create an ever stronger, more inclusive international tax system building on existing international cooperation. A UN Framework Convention has the potential to play an important role in supporting this ambition.

The UK therefore remains committed to working in partnership with other members and stakeholders to ensure we produce the Framework Convention and protocols that receive broad approval from Member States. To achieve that, we believe it is crucial that the commitments are drafted at a high enough level so as to be future proof and to help secure the widest buy in from members that would reflect that the framework can be. Convention is intended to establish the framework for ongoing cooperation. We also believe that high quality economic and legal analysis will be crucial to assess the interaction between commitments in this Framework Convention and those in other international agreements and any impacts on global trade. We encourage the Committee to make a plan for commissioning such work during 2025.

Similarly, we believe that the process would benefit from building on expertise from all relevant international and regional organisations, such as the Platform for Collaboration on tax, the OECD G20 inclusive framework on Base Erosion and Profit Shifting, the Global Forum on Tax Transparency and Exchange of Information and the African Tax Administration Forum, among others. We encourage the Committee to see set out a plan for how to achieve this. Join up before the end of 2025. We welcome the opportunity to discuss these important issues over the next few days and will engage constructively with all partners. Thank you.

Thank you Saudi Arabia, followed by Morocco and Nigeria. Thank you, Chair. I will deliver my remark in Arabics.

Mr. Chair, ladies and gentlemen. Peace and blessings of God be upon you all. At the outset, the Kingdom of Saudi Arabia would like to commend the efforts made by the Chair of the Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation as well as the co leads of the work streams. And we also commend the efforts of the Secretariat in preparing and publishing issues notes for the work streams.

Mr. Chair, in this regard, we look forward to completing the Committee's work through alignment and coordination among the different work streams, as well as focusing on urgent tax matters that require actual solutions at the international level. We also look forward to constantly enriching our work by integrating capacity development into all work streams. As for the commitments stipulated in the terms of reference of the Framework Convention, we believe that these commitments should be phrased and drafted in a clear manner consistent with the outcomes of the technical discussions held in the work streams on the first and second work streams in order to avoid establishing new irrelevant commitments. In the meantime and within the framework of working to find solutions to tax challenges, we must focus on addressing tax challenges of crucial importance without reconsidering issues and measures that are already effective today.

Following such an approach will contribute to modernizing outdated tax systems that have not kept pace with global economic changes. This would also extend bridges of cooperation in the prevention and resolution of tax system dispute, which would inevitably help support States that are facing capacity development challenges. This is a crucial aspect of our ongoing work in order to transform agreed outcomes into tangible results. Given our keenness to achieve practical and feasible results within the framework of international tax cooperation, we wish to affirm that work extending tax matters is in conclusion, we reaffirm our continued support for cooperation and joint coordination with other states to continue working to achieve the aspired outcomes of international tax cooperation. Thank you, Shukran thank you.

Thank you Morocco, followed by Nigeria and Pakistan.

Thank you Mr. Chair Mr. Chair, distinguished delegates Morocco aligns with the statement delivered on behalf of the African Group and would like to make the following statement in its national capacity.

Morocco would like to commend the dedication and the progress made so far under the three work structure and to reiterate its commitment to contribute to the successful development of the Framework Convention, recognizing it as the platform to establish an equitable and effective international legal framework to address our current and future tax challenges. Morocco is fully committed to advancing multilateral tax governance system that is equitable and transparent and that support sustainable development and domestic resource mobilization. The United Nations Framework Convention must serve as a flexible legal foundation for future protocols and mechanisms that reflects the principles of equity, transparency, inclusivity and the right of jurisdictions to a fair share of taxation of income generated within their borders. In this regard, Morocco supports that these commitments be included in the Framework Convention, including terms. Morocco supports the commitment to prevent and resolve cross border tax disputes, emphasizing that the language used in the Framework Convention should be concise and flexible, focusing on the principles of fairness and legal certainty and avoiding overly prescriptive and detailed rules that would be better addressed in the Protocols.

Morocco and Alliance Attacks Code cooperation should not just be about addressing global tax gaps, but also about contributing to sustainable development and ensuring that developing countries can strengthen their own tax systems. Finally, we reiterate our strong commitment to contributing constructively to discussions and supporting the establishment of a framework that lives up to the aspirations, rights and interests of our countries thank you very much.

Thank you. Distinguished Delegate of Nigeria, followed by Pakistan and Canada, the Chair, Excellencies and distinguished Delegates. Nigeria aligns fully with the submissions of the African Group and in addition wishes to make the following comments. 1. Nigeria's participation in this process of developing the United Nations Framework Convention on International Tax Cooperation and the early Protocols is with a clear vision of ensuring an effective global tax environment that works for all.

The vision of building a truly inclusive, effective and future proofed framework that reflects the realities of all countries, particularly developing countries, and delivers fair and equitable outcomes in the international SARC system should not be sacrificed on the altar of legalism, technicalities and politicking. As regards the Framework Convention itself, Nigeria is of review that the Convention be anchored in broad language that allows for flexibility and adaptability as the tax environment continues to evolve.

As much as Nigeria agrees that priority be accorded the early Protocols, we believe that effective and strong governance structures including issues of conference of the Parties, well resourced Secretariat and effective subsidiary bodies be institution instituted in the Framework Convention itself as regard work stream two, that is Taxation of cross border services. Nigeria recognizes the inadequacies of current tax rule in a digitalized and service driven global economy which unduly denies countries of source of due tax revenue. Therefore, Nigeria will support a broad and future proof scope that covers all cross border services without requiring a physical presence and that includes all technology driven services. We will support the adoption of new nexus rules such as significant economic presence and the like. The Protocol should provide for a system anchored on equity, simplicity, efficiency, neutrality and flexibility and should also provide practical administrable solutions that enables domestic resource mobilization for all countries on work stream three, that is Prevention and resolution of tax disputes.

Nigeria support the design of a universal framework capable of of addressing both bilateral and multilateral disputes. We call for preventive mechanisms such as joint audits, cooperative compliance programs and improved risk assessment backed by commitment on timely and effective exchange of tax relevant information including through a central public country by country reporting platform. In all, Nigeria believes that our collective objective must be to create a framework that corrects systemic imbalances, ensures a fair allocation of tax and rights, removes barriers to sustainable development and strengthens the ability of all countries to combat tax avoidance. Finally, Chair Nigeria stands ready to work constructively with all delegations to deliver a framework conventional protocols that are principled, inclusive and responsive to the needs of all nation and of all time. We must seize this opportunity to shape an international tax order that is just, balanced and capable of meeting the fiscal needs of all.

I thank you very much.

Thank you. Distinguished delegate of Pakistan, followed by Canada and Piro.

Tan is pleased to participate in this historic process to advance a comprehensive and inclusive framework for international tax cooperation. We thank you, the members of the Bureau and the Secretariat for your efforts leading up to this important first session.

Mr. Chair, the need for fair and effective international tax cooperation has never been more urgent. The current global tax architecture continues to reflect outdated dynamics and offers insufficient solutions to the challenges faced by developing countries. As a result, vast sums continue to be lost annually through tax avoidance, evasion and illicit financial flows. Funds that could otherwise be used to finance development, reduce inequality and strengthen national resilience.

We believe that these negotiations mark a turning point. The adoption of General Assembly Resolution 79235 has given us a clear mandate to elaborate a universal and equitable framework convention by 2027. Mr. Chair, Pakistan supports a robust and ambitious framework convention in our view broadly, the Convention must ensure a fair distribution of taxing rights, particularly through the reaffirmation of source based taxation principles support simplified and administratively feasible rules that reflect the realities of developing countries strengthen cooperation against illicit financial flows, including through effective exchange of information and capacity building include non binding scalable mechanisms for dispute prevention and resolution while respecting national legal systems and consider specific considerations for the least developed and developing economies whose economies are particularly dependent on corporate income taxes and are disproportionately impacted by the base erosion and profit sharing and illicit financial flows.

Mr. Chair, this is not just a technical negotiation. The outcome of this process will shape the global economic landscape for decades. For too long, international tax rules have failed to protect the needs and realities of developing countries. Pakistan believes this process must correct the structural inequalities of the current system and shift the center of gravity to the United Nations.

We must utilize this opportunity to build a just and inclusive international tax order. Pakistan looks forward to working constructively with all delegations and with the shared commitment to an inclusive, equitable and effective outcome. Thank you.

Thank you. Distinguish delegate of Canada followed by P and Philippines.

Thank you. Thank you, Mr. Chair. I will deliver my remarks in French.

First of all, on behalf of the Canadian delegation, I would like to sincerely thank the Chair and the co leads of the work streams and the members of the Secretariat for the work that they have done since the last session. I would also like to thank the members of the Committee that participated in the work stream's work, which we followed with a great deal of interest. It remains Canada's intention to actively participate in the development of the Framework Convention and its protocols to advance the inclusiveness and effectiveness of efforts for international tax cooperation.

By way of introductory remarks, allow me to comment briefly on two issues related to the Convention which are at the heart of our concerns at this stage. First of all, we share the opinion voiced by several Member States, that the Framework Convention should chiefly aim to establish a consensus based framework that will guide future efforts on international tax cooperation and to ensure the preserve the practical implementation of this to subsequent initiatives, including the Protocols that will be established under the Convention. We were of the view that this approach is in line with the end goal of a Framework Convention and will contribute to the success of a Convention by minimizing the possible implications of the Convention when it comes to respect for the tax sovereignty of States. We are also of the opinion that it would be preferable for the commitments to be closely aligned with the text that was included in the text of the Terms of Reference.

While we recognize the challenges that this represents for the Committee and the Secretariat, we encourage the Committee to begin the discussion of the other provisions that should be included in the Framework Convention as quickly as possible. We believe that it is important, given the interactions between the various different provisions, for the members of the Committee to be able to have an overview of the Convention and its content precisely so as to be able to identify and evaluate the interactions between the different provisions. What's more, we believe it is particularly important to advance the discussion on the objectives of the Convention and the principles that should guide the scope of it, because those objectives and principles should enlighten and inform the formulation of the commitments that should be included in the Convention. We are of the opinion that greater certainty over the nature and the formulation of those objectives and principles would facilitate the discussion over the possible commitments.

To conclude, if I may make a last comment on procedure, my delegation would like to encourage the the Committee to review its modus operandi on the work streams. We believe that the frequency of the meetings thus far does not facilitate the engagement of delegations because of the significant investment of time and resources that participating in this meeting requires from delegations. The late circulation of documents is an additional obstacle to the participation of members of the Committee because it only gives delegations a very small amount of time to prepare for the meetings. In our view, this practice does not contribute to the aim of inclusive and productive discussions, and for that reason we invite the Committee to review its practices going forward.

We hope that the Committee will be able to address these issues in the coming days, and I reiterate the intention of my delegation to participate actively in the development and Negotiation of the Framework convention. Thank you, Mr. Chair.

Thank you. Distinguished Delegate of Payroll, followed by Philippines and Zambia.

Muchas Gracia. Thank you very much, Mr. Chairman, for giving us the floor on the Framework Convention. Peru considers that since the commitments primarily will be fleshed out in the early Protocols and future protocols, they should be at a high level and they should be drafted using broad principles based language. Moreover, we believe that it is important that we also begin the discussions on the other elements that make up the Convention, such as its objectives and its guiding principles, because this will substantially guide the scope and content of the principles that will be adopted on Protocol 1. Peru welcomes the work of the Intergovernmental Committee to establish provisions that allow for the equitable designation of tax rights on income derived from the provision of cross border services.

In this context, we consider that this Protocol should encompass all forms of cross border services and should allow States to apply taxation mechanisms on gross revenues. Nevertheless, we remain open to examining alternative proposals that may be made on these subjects and also on the definition of what is covered going beyond an income tax. And lastly, on Protocol 2, Peru considers that this should not include mechanisms for the prevention and resolution of disputes that are strictly domestic in nature and it should not involve cross border transactions, which in English is purely domestic disputes. We reiterate our commitment to contribute constructively to achieving a successful result and a successful Convention. Thank you.

Thank you. Distinguished Delegate of Philippines.

Mr. Chair, distinguished delegates, it is our pleasure to participate in this first session of the Intergovernmental Negotiating Committee on the United Nations Framework Convention on International Tax Cooperation. For Developing nations. Effective international cooperation in tax matters is not merely a technicality. It is a fundamental pillar for achieving sustainable development, mobilizing domestic resources and ensuring a just global economic order.

We believe that this Convention presents a crucial opportunity to establish a truly resilient, inclusive and equitable framework that addresses the unique challenges faced by countries like ours. The ultimate goal is to create a system that supports domestic resource mobilization and contributes to the achievement of the Sustainable Development Goals. We are committed to a process that is transparent and allows for a full participation for the full participation of all stakeholders. Our collective success will depend on our ability to work together and find common ground on the technical and substantive issues before us. On how the Framework Convention and the Protocols should be drafted.

We echo the comments of other members of the Framework Convention. Other members that the Framework Convention contains high level provisions that are not self executing and that the specifics of the provisions should be reflected in the individual protocols. In our comments to work streams, 1 and 2 the Philippines has consistently emphasized the need for international tax rules that are firmly rooted in the realities of developing economies. We have highlighted the substantial challenges posed by complex tax disputes, which are often resource intensive and time consuming. We advocate for practical and administrable solutions that are tailored to the capacities of developing countries.

Furthermore, we believe that the framework must recognize the critical role of market jurisdictions in value creation, particularly within the digital economy, and reinforce the primary principles of source based taxation as a vital tool for domestic resource mobilization. Regarding Workstream 3 the Philippines strongly supports an approach to dispute resolution that prioritizes flexibility and broad participation. We believe the Protocol should offer a comprehensive suite of dispute prevention and resolution mechanisms, allowing Member States to opt in and opt out of specific provisions based on their national legal frameworks, administrative capacities and policy preferences. This opportunity is crucial as it acknowledges the diverse circumstances among nations and ensures that the Convention remains practical and relevant for all. Our commitment is to a framework that fosters genuine cooperation while respecting national sovereignty and promoting equitable outcomes for every country.

We thank the Chair and the Secretariat and the CO heads of the work streams for your hard work and leadership. Thank you.

Thank you. The floor now to the distinguished Delegate of International Chamber of Commerce.

Thank you. Thank you. Mr. Chair. I have the honour to deliver the General Statement on behalf of the International Chamber of Commerce, representing businesses of all sizes and from all industries across the world.

As Permanent observer to the United nations, we welcome the opportunity to provide input on the draft Issues Note for the Framework Convention, ICC and the global business community advocates for a global tax system built on the foundation of stability, certainty and consistency, which we believe is essential to foster cross border trade and investment and ultimately the achievement of sustainable development goals. In reviewing the draft Issues Note, we note the Work Plan's prioritisation of drafting specific commitments before other provisions of the Framework Convention. However, we would emphasise the crucial importance of addressing fundamental principles early in the process. The principles of tax certainty and the recognition of taxpayer rights and appropriate safeguards were acknowledged by many countries during the Terms of Reference negotiations but formally deferred to a later stage of resolution. We believe that these principles are not merely procedural, but are fundamental to ensuring a balanced, fair and effective international tax framework.

These principles should firmly be incorporated before detailed drafting begins. Turning to the commitments outlined in the Draft Issues Note, we greatly appreciate the reference to prevention and resolution of tax disputes. In this context, we believe it is of paramount importance to recognise the active participation of taxpayers in dispute prevention and resolution mechanisms. Meaningful involvement of taxpayers who possess crucial facts and information is essential to the legitimacy, effectiveness and timely resolution across border disputes. It's also important to explore alternative dispute resolution methods like arbitration or mediation, as well as mechanisms to prevent disputes like through cooperative compliance.

The ICC cautions against abroad broad and undefined debate about fairness in the allocation of taxing rights. Such a subjective approach risks significant delay and frustration and fairness should stem from transparent, objective and legally binding rules that ensure predictability and due process for all. We also call for the explicit inclusion of tax certainty as a guiding principle throughout the Convention. In conclusion, the ICC would like to reiterate the vital role of the taxpayer and taxpayer participation across all work streams. Our global business community can provide practical examples and insights that are indispensable for developing effective and predictable tax solutions.

Which is why we continue to suggest the formation of Business Advisory council that can inclusively represent companies from around the world to provide practical and constructive contributions to the process. Process. We hope members to countries can further consider this proposal. Thank you, Mr. Chair.

Thank you, Distinguished Representative of African Tax Administrative Forum.

Thank you, Chair, for giving us the floor. The African Tax Administration Forum is a platform for 44 African countries on tax issues and we want to identify with the statements supplied by the distinguished delegate of Ghana on behalf of our members. We also want to identify with the statements supplied by Nigeria, Kenya, Tanzania and a few others. We are identifying and align with those statements. ATAF is here, Chairman.

To constructively engage with Member States and other stakeholders with a view to furthering the very critical objective of this Committee. Our participation is promised on three grounds. One, to support our members in whichever way possible to further the very noble objective of this process and two, to support a robust future, proof and enduring Framework Convention. In this sense, we call for speedy elaboration of the Convention in manners that ensure flexibility and adaptability to changing international landscape. We underline the need to ensure the ability of the Framework to deal with both current and future issues of international tax.

We also call for immediate elaboration of the governance architecture of of the Framework with no further delays. Chair. The three element pillars of our engagement is to support the elaboration of the first Early Protocol on Cross Border Services. We call for the Members to ensure that the Protocol is given the widest possible scope as to resolve critical issues that bothers our members. Inclusive of the abuse of Intergroup services, often used as vehicles for shifting profits away from from our jurisdiction, as well as a key enabler of illicit financial flows.

Chair. In general, we have observed a bit of constraint on the side of our members when it comes to support of the Secretariat owing to dwindling resources. We observe that this is not consistent with the resolution 79235 which called for reverse resources of this Secretary to support this process. We call on our members and the host organization to ensure that the object and intent of the resolution in terms of support to this process is realized as this is critical to getting this work stream to the desired finishing line. Chair we supply this comment in addition to written comments which ATAF has submitted in response to the issue Notes we thank you Chair.

Thank you Distinguished representative of Oxfam.

Thank you Chair for the opportunity to speak. My name is Evelyn Kavenge and I speak on behalf of the aforementioned organization as well as the Tax Department, Justice Network Africa as well as the African Group, the African Civil Society Organization's Working Group on the UN Tax Convention. We align with the statement made by Ghana on behalf of the African Group and on Work Stream 1. We acknowledge the importance of addressing the historical imbalance of taxing rights through the commitment on fair allocation of taxing rights. While taxing where economic activity takes place and where value is created is seemingly a logical principle, this is obviously a principle that has been violated in the past and just recently.

The international deal struck by a few rich countries in order to exempt one country from the implementation of from the implementation of Pillar 2 illustrates this and it illustrates how rich countries have been shaping the international tax account architecture. There is no need for worries about duplication. Amongst other similar worries. We emphasize that Member States are here to rectify a historical run where taxing rights have been imbalanced and particularly affecting Africa as well as Global south countries. Therefore, as the Working Group we propose an additional element in paragraph 14 of international equity.

This will future proof the Convention and ensure that there is both economic as well as political fairness on WorkStream 2. We remind member States of the importance of this Protocol to many of our countries. According to UNCTAD services, add an estimated economic value of 61% to developing countries. Many of these countries, particularly African countries and other global south countries are net importers of these services. Therefore, we emphasize the importance of ensuring that the rules proposed under this Protocol should be simple and easy to administer.

While much emphasis has been placed on nexus and profit allocation rules, we also encourage revisiting complex transfer pricing rules. We emphasize that technical assistance has not been enough. We need to create simple rules including non tax transparency standards such as country by country reporting which has been mentioned by Nigeria so that even the least developed amongst us can benefit and this will embody the true definition of international equity. Thank you.

Thank you, distinguished representative of ccfd.

Merci. Thank you, Chairman. I would like to speak about the ambition of this historic process which gathers us here today. The mandate provided by the United Nations General assembly to this Convention on International Tax Cooperation is clear. We're not going to be writing a corpus of non binding standards and optional mechanisms and weak principles and commitments that can be reneged on.

Rather, we need to set up a fair, inclusive, transparent and equitable international tax system that can really fuel sustainable development and can finally give an equal voice to each country.

If this means breaking with the current unfair tax system, then yes, we will fully support the most ambitious possible process. It is a question of justice. This process cannot be seen to be duplicative. International cooperation is not threatening States sovereignty, but rather tax evasion and avoidance are making this the case because a small group of countries are currently able to impose unfair practices on all countries, both in the north and the south and prevent countries from accessing tax receipts. This is now therefore a requirement.

This cooperation can not just be complementary to the OECD framework. We have seen deadlock in that process and we have seen it undermined by significant exemptions and carve outs. And these rules will never be global. However, we are allowed to be hopeful today. We can take this opportunity and we can make this negotiation process a success.

We should not hesitate and we must. There is too much at stake for us to prevaricate. We need to ensure that we are successful in this process so that countries can finance their health systems, their education systems and can combat climate change. That is what is at stake here. To provide countries with the means for them to finance their futures.

Thank you.

Thank you, distinguished representative of an institution for Social Economic Studies.

Thank you very much, Mr. Chairman. I'm Adrian Falco and I'm speaking on behalf of inesc, which is member of a member of the Latin Dad Network. I would like to take this opportunity to ask all delegations present here to ensure the full participation of civil society in this process. I would like to recall what was said in August 2017 by Antonio.

You are the most important part of the process. Non governmental organizations, the United nations has committed to work with you to build a fairer and more prosperous future for all. For reasons that we're not aware of, given that we've fulfilled all the requirements, many of the organizations that do not have EQUISOC status and which have followed this entire process and participated in negotiations last year, are not here today. This is a critical stage for us to Define and structure a robust convention that can really lead to genuine international tax cooperation. And that is why we call on you to ensure that these voices from civil society are not ignored.

I would like to mention the importance of bringing the FFD4 outcome document, the civil commitment to this process, because this contains relevant procedures for this process. And this includes promoting efficiency in tax systems in order to increase revenues, to promote progressive tax systems and to join efforts to reduce tax evasion of high net worth individuals and to ensure international cooperation in these areas, while also respecting state sovereignty as well as promoting equitable public expenditure. This also means the effective use of natural resources and ensuring a gender perspective in the process. Promoting the consideration of the climate and the environment in line also with national circumstances and the national priorities for sustainable development and strategies to eradicate poverty, while also respecting state sovereignty. This can also include taxation on pollution.

Countries need to be encouraged to include social protection systems within all of this process. This also means protecting everyone's fundamental rights and human rights. This includes economic, social and cultural rights and civil and political rights. This must be enhanced. These must be protected at all times without any kind of discrimination.

This convention must therefore include a commitment to ensure that these rules are designed in line with with respect for human rights and sustainable development. Thank you.

We have heard all the speakers in the list of speakers and no more requests for the floor. So by this now we get a request from disappeared again.

Okay, So I think we are done for today. Okay. African Union, the floor is yours.

Thank you very much, Mr. Chair, and thank you to all the delegations.

The African Union statement aligns with the position of the Africa Group and at the onset we would like to sincerely congratulate the newly elected Bureau members and express gratitude for the detailed issue notes and the thoughtful consultations. We gather at a moment of historic juncture as the global community under the UN designs an inclusive and just International Framework Convention on Tax Cooperation. This is not just another meeting. It is the first time in history we are coming together to create a new shared principle driven framework. The recent G20 announcement regarding Pillar 2 exemptions reminds us of the current broken and unfair tax architecture.

The African Union is here for with hope and determination to co create a system that works for all, rooted in equity, transparency and the sovereign right of every nation to raise revenue justly. The African Union priorities across the work streams are clear. On Work Stream 1, we emphasize developing a convention, structural and governance elements such as the Conference of Parties, the Secretariat and Subsidiary bodies due to their functional role and the need for sufficient elaboration time. On Work Stream 2, we believe the protocol should be future proof covering digital and emerging services. It must uphold the principle of taxing where it economic activities and value occur, follow simple rules and include a multilateral solution to overcome existing tax treaty limitations.

On work stream three, we urgently need to address cross border tax disputes that disadvantage countries with limited access to mechanism like mutual agreement procedures and arbitration. We call for a fair, accessible and balanced dispute resolution framework that avoids replicating investor state arbitration inequities. Mr. Chair, on a matter of institutional importance, implementation of Resolution 79 233, particularly operational paragraph 12 concerning necessary facilities and resources, including a technical Secretariat, has been unacceptably slow. While recognizing UN liquidity constraints, this process must be a priority.

It is transformative opportunity to correct systematic imbalances and place the UN at the heart of global economic governance. The credibility of this process depends on timely institutional support and adequate resourcing. We urge the Secretariat and the wider UN system to accelerate implementation and use and ensure these efforts receive the backing it deserves. This unique opportunity to shape global tax cooperation belongs to all of us. It is inclusive, transparent and must remain grounded in the fundamental principle of equity among nations.

We thank the delegations and we thank all the delegations for their engagement and call on everyone to bring their best ideas, boldest thinking and deepest commitments to justice to the table. It is in this set of principles that we will ensure that developing economies and all economies are able to mobilize their domestic resources and channel them to effective development. Thank you very much.

So now we don't have any more requests for the floor, so I think we are done now with general statements. And before adjourning the meeting, I just would like to recall that our next meeting will be tomorrow morning, Thursday the 5th of August, in the same conference room at 10am so thank you all and looking forward to see you tomorrow. And just final note for the colleagues, our meeting is still the same. We're going to meet this afternoon to coordinate, so the colleagues are not released. We still have some work to do.

Thank you all and I announce the meeting adjourned.