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On the last day of #TaxCooperation #INC3, delegates concluded initial talks on the prevention and resolution of #tax disputes

Chair Ramy M. Youssef called on all to actively participate in intersessional work in the lead-up to #INC4 in February 2026

Read ➡️ enb.iisd.org/un-framework...

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At the #TaxCooperation #INC3, delegates are addressing how best to resolve information asymmetries in the prevention and resolution of #tax disputes, specifically in the field of transfer pricing, discussing access to transfer
pricing databases to strengthen tax administration capacity.

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On the last day of the #TaxCooperation #INC3, delegates are finalizing discussions on the resolution of #tax #disputes, considering how best to strengthen mutual agreement procedures (MAPs), which are central to dispute resolution, but have also been inadequate when applied on their own.

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At #TaxCooperation #INC3, some countries intimated they would require capacity-building to assist them to address domestic tax disputes

Others underscored even sharing best practices on domestic tax matters would impinge on national sovereignty

Read ➡️ enb.iisd.org/un-framework...

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At the #TaxCooperation #INC3 in Nairobi, delegates have embarked on a discussion on #tax #dispute #resolution, focusing on the mutual agreement procedure (MAP) as a key mechanism for resolving disputes arising under tax treaties. Can mandatory arbitration strengthen this mechanism, or is it unfair?

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Delegates at the #TaxCooperation #INC3 are addressing prevention of tax disputes, discussing whether the Protocol should provide a legal basis for cross-border administrative cooperation in tax dispute prevention.
"It is better to prevent the fire than to quench it," says Zambia.

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At the #TaxCooperation #INC3 on Tuesday morning, delegates are continuing discussions on the modalities of the second early Protocol on the prevention and resolution of #tax disputes, focusing on the future Conference of the Parties work in providing guidance on tax disputes.

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At #TaxCooperation #INC3 Monday in Nairobi delegates debated: should the second early Protocol on the prevention and resolution of #tax disputes be universally applicable?

Or should parties be able to opt-out of implementing its mechanisms?

Highlights ➡️ enb.iisd.org/un-framework...

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Delegates discussing a new #taxcooperation agreement at #INC3 hear that "Protocols are meant to implement a convention, not the other way around," with some stakeholders underlining that the current discussions will only lead to further fragmentation of the global tax regime.

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Delegates at #TaxCooperation #INC3 continue to address the conceptual aspects of a future Protocol on dispute prevention and resolution, with some opposing the inclusion of mandatory #arbitration as a core dispute resolution mechanism, explaining that it is costly and "may undermine sovereignty"

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In discussions on the Protocol on #dispute prevention and resolution, #INC3 on #taxcooperation considers how to operationalize the "optionality" envisioned under the Protocol, with many countries preferring a case-by-case application of mechanisms under the Protocol.

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Delegates at #TaxCooperation #INC3 in Nairobi have reconvened to address the second early Protocol related to the prevention and resolution of #disputes, considering whether this Protocol should be optional, and/or which mechanisms under the Protocol would be optional, given existing mechanisms.

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Delegates at #TaxCooperation #INC3 in Nairobi discussed Friday how establishing Centres of Excellence in tax administration could help stronger tax cooperation

Highlights ➡️ enb.iisd.org/un-framework...

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#INC3 Chair Ramy Youssef (Egypt) closes #taxcooperation talks at 3.45 pm on Friday, after delegates hear a brief update on work done towards Protocol 1 on taxation of cross-border services. Negotiations will resume Monday, 17 Nov, on Protocol 2 on prevention and resolution of tax disputes.

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#INC3 on #taxcooperation discusses Workstream II on taxation of income derived from provision of services in a digitalized and globalized economy. Chile, Co-Lead, says paper on usage of economic terms & concepts will come out for Feb 2026 meeting; and modelling of possible approaches by Aug 2026.

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At #INC3, Nigeria explains “capacity” for #taxcooperation is more than technical skills, it's also access databases & tools for benchmarking e.g. on transfer pricing. Chile supports centres of “access and knowledge” so countries can choose from others' approaches, what will work for them.

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At #INC3 on #taxcooperation, countries brainstorm issues in capacity building, incl addressing needs of SIDS & LDCs, transferability of IT and data management systems, and sustainability of efforts. Brazil suggests an informal group to identify the needs; Lesotho proposes Centers of Excellence.

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Post image Chair Ramy M. Youssef, Egypt

Chair Ramy M. Youssef, Egypt

Daniel Atwere Nuer, Ghana, Workstream 1 Co-Lead

Daniel Atwere Nuer, Ghana, Workstream 1 Co-Lead

Preventing and and resolving cross-border #tax disputes will require action at multiple levels

Countries at #TaxCooperation #INC3 debated how far the new Framework Convention text should go in prescribing—or even mentioning—actions in the domestic domain

Read ➡️ enb.iisd.org/un-framework...

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#INC3 on #taxcooperation revives discussion of Article 9 on illicit financial flows. India notes the UN Statistical Commission’s work on #SDG16 indicators, including measurement of illicit financial flows (indicator 16.4.1).

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On capacity building for #taxcooperation, delegates offer views on whether this should be a standalone article or integrated as a clause in other articles. The African Union calls for consolidating all aspects within Article 11 of the new framework convention.

#INC3

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#taxcooperation talks address prevention & resolution of tax disputes. China, Morocco & others request deleting text on “domestic” dispute resolution mechanisms. #INC3 Chair explains the COP could provide best practice guidelines. African Group suggests replacing “domestic” with “appropriate.”

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What is a harmful #tax practice?

Is it something individuals, companies, or governments do?

These questions occupied delegates at #TaxCooperation #INC3 as they discussed examples and possible remedies

Highlights ➡️ enb.iisd.org/un-framework...

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#INC3 discusses #sustainabledevelopment in relation to #taxcooperation. Some States prefer brief text, while others request expanding on concepts. Brazil proposes referring to domestic resource mobilization, UK calls to include "polluter pays" principles, & ILO cites social protection standards.

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Youth advocates at #INC3 on #taxcooperation say harmful tax practices reduce funding for education, healthcare, social protection and other necessary services. Children & Youth Major Group call for transparency on use of private investment vehicles like trusts and shell entities.

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#INC3 #taxcooperation talks stall over how the draft framework convention relates to existing processes, esp OECD forums. Jamaica suggests focusing on how existing arrangements fall short. Tanzania says developing countries legitimately use tax incentives to promote industrialisation & job creation.

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On day 3 of #INC3 on #taxcooperation, States discuss ways to combat harmful tax practices, including by multinational enterprises that may shift assets & income across borders. Zambia calls for definition of "harmful tax practices." India says joint action must not impede legitimate tax competition.

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Should the super-rich pay more tax?

Many would say yes — but identifying so-called high net-worth individuals is contentious

At #TaxCooperation #INC3, governments are considering how to improve data sharing to enable #tax collection

Highlights ➡️ enb.iisd.org/un-framework...

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At #INC3, some warn against potential overlaps between the draft Framework Convention on #taxcooperation and other multilateral arrangements, while others highlight possibilities for a unified framework, including mutual administrative assistance and capacity building to detect tax evasion.

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At #INC3 on #taxcooperation, countries discuss the text of an article on "mutual administrative assistance", covering info sharing and capacity building. Most agree information exchange is fundamental for international tax cooperation — but also have concerns about data protection and privacy.

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At #INC3 on #taxcooperation the BAHAMAS regretted that SIDS "are being forced" to implement new types of tax, while having sparse resources in administrative capacity. He called for special provisions for SIDS to be made under Art. 6 on mutual administrative assistance.

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