Global Tax talks back on the agenda

The Fourth Session of the Intergovernmental Negotiating Committee (INC) on the UN Framework Convention on International Tax Cooperation is set to begin from 2 – 3 and 5 – 13 February 2026 at the United Nations Headquarters in New York.

During this session, the focus will remain on the draft text of the Framework Convention and the two early protocols on taxation of income from cross-border services, as well as dispute prevention and resolution. It follows the Third Session of the INC that was held in Nairobi, Kenya, in November 2025.

The process of the UN Framework Convention on International Tax Cooperation, actively championed by civil society and the Africa Group, has laid a firm foundation for an international tax system capable of delivering on the mandate for sustainable development and addressing global inequalities. Reflecting on the process to date, Ms. Chenai Mukumba, Executive Director of Tax Justice Network Africa (TJNA), commented:

“In Nairobi, the Africa Group led with conviction and clarity, advancing proposals aimed at restoring taxing rights to the Global South. While we were able to push back against multiple attempts to dilute the ambition of the Framework Convention, significant work remains in New York.

This process must ultimately deliver the fiscal space urgently needed to support public services, strengthen climate resilience, and uphold dignity for our people. The global community must now build on the momentum from Nairobi and deliver a robust and fair Framework Convention by 2027.”

Key Areas of Focus in the Fourth Session in New York, February 2026 

Building on the substantive negotiations in Nairobi, the New York session is expected to center on three critical issues: how taxing rights are allocated, how countries cooperate to combat tax abuse, and how transparency through the exchange of information is strengthened.

Article 5 of the most recent draft Framework Convention addresses the fair allocation of taxing rights, challenging the longstanding reliance on permanent establishment as the primary basis for taxing multinational enterprises.

It seeks to rebalance global tax rules by enabling countries, particularly in the Global South, to tax multinational entities based on where users are located, value is created, and real economic activity takes place.

While efforts to strengthen source-based taxing rights are commendable, there remains significant scope to go further. This provision is therefore expected to generate robust, but necessary, debate, with the Africa Group continuing to call for clearer and stronger language that allocates a greater share of taxing rights to developing countries.

Article 9 of the latest draft of the Framework Convention on Mutual Administrative Assistance (MAA) is also expected to attract divergent views among Member States. The article seeks to establish broad measures for mutual administrative assistance to combat tax evasion, illicit financial flows, and base erosion by multinational enterprises.

MAA is a foundational pillar of international tax cooperation, playing a central role in advancing exchange of information and strengthening tax transparency. In New York, discussions on this article are likely to focus on the role of the Conference of the Parties (COP), concerns around potential duplication with existing international frameworks, and the inclusion of public country-by-country reporting.

Notably, while exchange of information was previously addressed under Article 9, the current draft of the Framework Convention now contains a dedicated provision, Article 10, following proposals from civil society and Member States to treat exchange of information as a standalone pillar of international tax cooperation.

Reflecting on the progress made in Nairobi and looking ahead to New York, Ms. Mukumba stated:

“The consensus achieved in advancing the text is a clear victory for multilateralism. While there remains scope to further strengthen the framework, this moment deserves recognition. Our focus must now turn to ensuring that this promising text ultimately becomes a legally binding reality.”