Why the UN Tax Convention is advancing
By Attiya Waris
Something unusual is happening at the United Nations. A multilateral negotiation is moving forward — and I say that as someone who has spent years watching international tax reform start, stall, collapse, and get buried in diplomatic language and compromise. I was in New York in February, in the room, as the Fourth Session of the Intergovernmental Negotiating Committee concluded its latest round. The pace and seriousness of these negotiations surprised me.
Back in 2022, I stood before the UN General Assembly and called for exactly this: a UN-led global tax convention to address the hundreds of billions lost each year to corporate tax abuse and offshore evasion. Three years later, 110 Member States have signed on to the Terms of Reference, the negotiating sessions are running to a tight roadmap, and early drafting elements are in circulation. That is not nothing. In UN terms, it is remarkable.
But it demands explanation. Why is this process — patient, rigorous, and genuinely inclusive — moving when so many others have not?
The system was broken, visibly
The negotiations are taking place against the backdrop of a global tax system that has failed on its own terms. Over half of African countries still mobilise less than 15 per cent of their GDP in tax revenues, below the 20 per cent threshold the UN identifies as necessary to fund basic public services. The OECD's minimum tax agreement, for all its ambition, has already been hollowed out: the US carved out its own companies from the global minimum rate, and as former US Treasury Secretary Janet Yellen has warned, exempting US firms is likely over time to prompt other nations to abandon the regime altogether.
I said at the time that this was entirely predictable. The OECD was never truly multilateral. It was shaped primarily by wealthy nations and handed to the rest of the world as a settled matter. Developing countries, which depend disproportionately on corporate taxation precisely because their income tax bases are narrower, have had the least say in the rules that govern them most.
The UN convention is different in character. It is open to all Member States. Member states not in negotiations can return to them at any time. The fault lines are visible and contested in public: at the February session, developing countries pushed for taxing rights based on where customers are located and where value is genuinely created, rather than on physical presence alone. That is not a technical nicety. It is a question of whether countries like Angola will ever be able to tax the multinationals operating within their borders. In Financing Africa, I argued that the answer lies in treating multinationals as unitary entities and taxing them on their global activities. That idea is now on the table at the UN.
Why the talks are moving: material interest, not altruism
The honest answer is that states stand to gain materially from success. International cooperation works best when governments can go back to their finance ministers and say: this will bring in revenue. For lower-income countries, with debt servicing consuming public budgets and development assistance in freefall, the appetite for agreement is driven by the knowledge that alternatives are running out.
There is also something else at work. When a state or group of states use tariffs, sanctions, and financial pressure as tools of coercion — when fiscal policy becomes the opening phase of conflict — governments on the receiving end start looking for rules that protect them. A multilateral tax convention is one such rule. States that want to reduce their vulnerability to unilateral economic pressure have strong reasons to want it to succeed. That calculation has sharpened considerably over the past year.
What this means for civil society
The negotiations are patient and rigorous because the subject matter demands it. Transfer pricing, the taxation of cross-border services, dispute resolution — these are not issues that lend themselves to slogans. Civil society organisations that have been effective here are those that invested in technical work: reading the proposals, understanding the difference between what negotiators say in the room and what ends up in the text, and showing up consistently across sessions.
The ask of academia is more important than ever before. The data makes the stakes vivid. Every dollar shifted offshore is not an abstraction: it is a hospital unfunded, a classroom without a teacher. Human rights cannot be delivered without resources, and resources cannot be fairly distributed without human rights. The convention is, at its core, a human rights project.
The ask of civil society is harder than many campaigns. It requires long-term commitment, specialist knowledge, and a willingness to work in spaces where progress is incremental and victories are rarely dramatic. But the payoff is structural — a binding framework that, over time, reshapes the rules under which multinational corporations operate worldwide.
The moment is now
The UN is not suddenly a reliable friend to economic justice. But it is a space where, under certain conditions — when states see material gain, when the political moment shifts, when academia and civil society have done the technical work — meaningful change becomes possible. Those conditions exist right now.
The question for civil society is simple: are you ready for the moment when your issue becomes negotiable? That means building relationships with the delegations currently shaping the text and being in the room, or being well-known to the people who are.
As a Swahili proverb puts it: wealth, if you use it, comes to an end; learning, if you use it, increases. The window is open. The work is to make sure it does not close without something worth keeping passing through it.
Attiya Waris is the United Nations Independent Expert on Foreign Debt and Human Rights and an Inaugurated Professor of Fiscal Law at the University of Nairobi. She is the author of Financing Africa (Langaa, 2019) and has advised governments and international institutions on tax, debt, and human rights finance across Latin America, Africa, the Middle East and beyond.