UN Tax Convention Wraps Second Session
The second session of the United Nations Framework Convention on International Tax Cooperation (the Convention) was concluded on 15 August 2025 with delegates intensifying discussions on dispute prevention tools (Workstream 3) and the feasibility of a UN-led transfer pricing (TP) comparables database (see Prevention and Dispute Resolution Protocol Debates Begin at UN Tax Convention Second Session (15 August 2025).
Gathered in New York last week, The Co-Lead guided the plenary through the following issues:
Fact-Finding Tools and Information Asymmetry
The plenary examined paragraphs 7 and 16 of the Issues Note, which address fact-finding tools and information asymmetry. Delegates acknowledged that information asymmetry remains a major challenge in resolving tax disputes. They highlighted that while tools and rules for gathering facts are critical, their design and application vary across jurisdictions. They examined which tools are most effective, how differences between legal systems (e.g. common law and civil law) affect their use and whether jurisdictions can rely on practices such as depositions or affidavits.
Comparable Databases
The plenary then discussed the possibility of the UN developing a TP comparables database. Delegates considered challenges jurisdictions face in accessing and using TP comparables — such as cost, data quality and technical capacity — and debated what safeguards would be essential to ensure taxpayer confidentiality if a shared or cooperative database were created.
The Chair opened the discussion on Agenda Item 6, guiding the Committee to consider the adoption of the report. The Rapporteur presented a comprehensive summary of the first and second sessions, highlighting all substantive discussions. The Committee will adopt the final report at its concluding session in 2027, in line with UN practice. This report will include a list of delegations that delivered statements under each agenda item and a record of all decisions made.
The Under-Secretary-General of the UN Economic and Social Council (ECOSOC) delivered closing remarks, thanking the Chair, Member State representatives, civil society, international organization partners, academia and the private sector for their contributions. He noted that with the scoping phase now complete, the workstreams would shift to developing concrete proposals, which will be presented at the plenary sessions in Nairobi in November 2025 and in New York in February 2026.
The Chair closed the session by announcing that the third session of the Intergovernmental Negotiating Committee (INC) on the UN Framework Convention on International Tax Cooperation will take place in Nairobi in November 2025. The three workstreams will continue to meet to refine ideas, build consensus and prepare preliminary proposals for that session.
Report from Eedee-Bari Nuah Bawoh, Associate, IBFD. Read all of our reporting on this via our Tax News Service (subscribers only).