On 7 June 2024, the United Nations (UN) published a ‘Zero Draft’ Terms of Reference (ToR) for a UN Framework Convention on International Tax Cooperation (Framework Convention) for public consultation. The deadline for comments is 21 June 2024. The draft ToR sets out the basic parameters and mechanisms of a Framework Convention, including its proposed objectives, principles, substantive and structural elements, and timeframe for negotiations. It also identifies certain priority areas to be addressed in early protocols including the taxation of the digitalised and globalised economy, cross-border services, and high net worth individuals. The draft also lists several additional topics that might be the subject of future protocols.
The UN’s move to ramp-up its efforts in international tax has thus far been discussed at a high level, with limited information on the project’s concrete ambitions. The ToR provides further insight into the potential scope of the proposed Framework Convention, indicating that the covered areas may indeed overlap with those addressed in other fora such as the OECD.