Department of the Treasury

UN Framework Convention On International Tax

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Treasury released the International Chamber of Commerce's response to draft issues notes for a UN Framework Convention on International Tax Cooperation. The ICC commentary addresses two workstreams: the first developing the framework convention text on fair tax allocation, dispute resolution, and sustainable development support; the second focusing on a protocol for taxing cross-border digital services income. The ICC emphasizes foundational tax principles—including tax certainty, taxpayer rights, and predictability—should precede commitment drafting to prevent fragmentation and deadlocks. It supports fair, independent dispute mechanisms with taxpayer participation, cautions against subjective "fairness" debates on taxing rights allocation, and proposes establishing a Technical Business Advisory Council with 20 business representatives (four per UN region) to ensure balanced input and transparency. The ICC stresses any new taxing rights approach must cohere with existing frameworks and that policy should support sustainable growth and cross-border investment amid growing complexity in international tax rules.

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