07 April 2026 UN Tax Committee's 32nd Session sets technical work program for 2025-2029 - key highlights - On 23-26 March 2026, the United Nations Committee of Experts in Tax Matters (the UN Tax Committee) discussed proposed workplans for its subcommittees and ad hoc groups covering a wide range of topics, including the UN Model Tax Convention.
- A sequence work program has been concluded. Several workstreams will be discussed on the next Committee meeting, expected in October 2026
- Businesses with significant presence in developing countries, digital business models, services operations, extractives, energy transition supply chains, complex transfer pricing profiles or emerging artificial intelligence (AI)-enabled compliance risks should monitor the developments closely.
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The United Nations (UN) Tax Committee met in New York on 23-26 March 2026 to consider the proposed workplans of the subcommittees and ad hoc groups established at its 31st Session in Geneva in October 2025. The proposed workplans address: the UN Model Tax Convention; the UN treaty negotiation manual; transfer pricing; the digitalized and globalized economy; tax administration and artificial intelligence (AI); indirect taxes; extractive industries; environmental taxation; wealth taxation; tax and gender; and dispute avoidance and resolution. The 32nd Session has produced a sequenced work program, with identified deliverables and expected reporting dates. Several workstreams are scheduled to return at the next Committee meeting, expected in late October 2026 in Geneva, with an initial report, an outline or substantially developed material. Though the UN Tax Committee does not have legislative power, in practice its outputs often influence treaty negotiations, domestic reform agenda, tax administration practice and capacity-building programs. Multinationals with significant exposure in developing countries, digital business models, services operations, extractives, energy transition supply chains, complex transfer pricing profiles or emerging AI-enabled compliance risks should therefore monitor these developments closely. The UN Tax Committee is a subsidiary body of the UN Economic and Social Council that develops practical guidance, UN Model Tax Convention provisions and related materials on international tax cooperation, with a particular focus on the needs of developing countries. Its work is carried forward both through biannual sessions and through subcommittees and ad hoc groups that draft technical outputs between sessions. The 31st Session in Geneva in October 2025 launched the Committee's 2025–2029 demand-driven agenda, establishing 11 workstreams intended to address the challenges that developing countries face in building fair and effective tax systems and strengthening international tax cooperation. This work matters to business for at least three reasons. First, UN outputs can shape the policy positions of finance ministries and tax authorities in treaty negotiations and domestic reform programs, particularly in jurisdictions that look to the UN for practical tools and source-country-oriented guidance. Second, many UN outputs are designed expressly for implementation by tax administrations, which can affect audit approaches, taxpayer service models, dispute practices and administrative expectations. Third, the Committee's work increasingly sits alongside the broader intergovernmental negotiations on a UN Framework Convention on International Tax Cooperation, creating the prospect that technical UN guidance may become increasingly important as countries seek practical ways to implement broader international commitments. What happened at the 32nd Session? The 32nd Session was structured principally around review of the proposed workplans for the new workstreams. (An overview of the workstreams is included in Annex 1 of this Alert.) Committee members raised comments on the terms of reference for each workplan, which will be adapted to take on the requests of the members. Each workstream now has a clear mandate, scope, sequencing and expected deliverables. Several workstreams will be addressed at the 33rd Session in Geneva expected in late October 2026, with either an initial progress report, an outline or a first substantive product for Committee discussion and guidance. The expected outputs for this session are included in Annex 2 of this Alert. Key takeaways for multinational groups Five points stand out for multinational groups. 1. The UN treaty and policy agenda is becoming more operational. A notable feature of the 32nd Session materials is the movement from broad topic selection to specific drafting programs, often with staged deliverables over three or four sessions. This is particularly visible in the work on the UN Model Tax Convention, the treaty negotiation manual, transfer pricing, value-added tax (VAT), AI, wealth taxation and tax and gender, where the proposed outputs are no longer merely conceptual but framed as manuals, guides, handbooks, sectoral guidance or draft papers intended for practical use. 2. Source-country and developing-country perspectives remain central. Across the workplans, the Committee repeatedly stresses that outputs should reflect the realities, priorities and administrative capacities of developing countries. That orientation is especially relevant in areas such as services taxation, source rules, permanent establishment issues, transfer pricing simplification, VAT collection on digital supplies, critical minerals, environmental taxation and AI deployment in revenue authorities. For multinational businesses, that suggests continued pressure toward rules and administrative practices that protect source taxing rights and enhance revenue collection in market and resource jurisdictions. 3. Several topics could affect future tax treaty practice. The work on the UN Model Tax Convention and on the digitalized and globalized economy is particularly important from a tax treaty perspective. The Subcommittee on the UN Model Tax Convention will initially prioritize work on the consequences of the Subject-to-Tax-Rule,1 definitions and source rules, while the Subcommittee on Taxation of the Digitalized and Globalized Economy will prepare an evaluation report on services permanent establishments and the treatment of services related to emerging technologies, including whether the 2025 UN Model Tax Convention adequately addresses them. Those outputs could affect future thinking on services nexus, source taxing rights, definitions of passive income and broader permanent establishment issues. 4. Administrative guidance will increasingly matter alongside legal rules. The work on tax administration and AI, indirect taxes, extractives, dispute avoidance, wealth, and tax and gender illustrate how much of the UN's value proposition now lies in administrative guidance rather than just in normative treaty text. This shift toward administrative guidance may not directly change legal obligations for taxpayers, but it can materially affect the way tax authorities approach risk assessment, audit selection, taxpayer service, refund management, data use, scrutiny of high-net-worth Individuals, cross-border VAT disputes and the design of internal governance safeguards for new technologies. 5. Businesses should watch the interlinkages, not just the individual topics. Many of the Conference Room Papers (CRPs) expressly identify dependencies and overlap. Examples include transfer pricing liaising with the UN Model Tax Convention and digitalized economy work on profit attribution to permanent establishments; environmental taxation coordinating with extractives, indirect taxes, AI and the UN Model Tax Convention; AI linking to VAT fraud, wealth taxation and gender bias; and tax and gender linking to indirect taxes, wealth and AI. For tax directors, this means that the significance of the UN program may lie as much in the combined direction of travel as in any one individual output. The Committee's work is likely to influence tax treaty negotiations, domestic reform or administrative practice in key markets. That is particularly relevant for groups with substantial exposure in developing countries. In practical terms, businesses may wish to do four things over the coming months: - Identify which of the UN workstreams are most relevant to the group's fact pattern and geographic footprint.
- Monitor the outputs expected for the 33rd Session in Geneva in late October 2026, as those outputs will be the first real indications of how the Committee intends to move from mandates to detailed guidance.
- Consider whether any internal policy or controversy teams should begin tracking UN developments in areas that have previously been monitored mainly through the Organisation for Economic Co-operation and Development (OECD) or domestic channels.
- Consider whether to engage with the UN Tax Committee or any of its subcommittees.
Annex 1 — Workstream-by-workstream summary and likely next steps | | Workstream | Description | Why it matters | Next steps | 1 | UN Model Tax Convention | The subcommittee's workplan is organized in two phases: the initial phase covers STTR-related changes, definitions, and source rules; later phases may address profit attribution to permanent establishments, PE concept and nexus rules, and other issues. A recommendation on a 2029 update is due by March 2027, with the first progress report expected in October 2026. | Can shape future treaty practice on source taxation, passive income definitions, service nexus, digital presence, and anti-base erosion measures. | Committee to receive the first progress report, informed by outputs from digitalized economy and transfer pricing workstreams. | 2 | UN Manual for the Negotiation of Bilateral Tax Treaties | Two-phase approach: first, align manual with the 2025 UN Model (including new articles and STTR); second, develop practical guidance on negotiation challenges (hybrid/digital negotiations, MFN clauses, bulk negotiations, visual tools). First progress report expected in October 2026. | May influence how developing countries approach treaty negotiations, framing discussions on services, resources, insurance, and anti-base erosion provisions. | First progress report expected, Workstream 1 entering discussion phase. | 3 | Transfer pricing | Four areas: update the 2021 manual, sector-specific guidance for ICT, guidance on unilateral APAs, and explore Committee work on profit attribution to PEs. Initial report on profit attribution due by October 2026; other work continues through 2028. | Addresses practical challenges in audits and controversy for developing countries, including intragroup services, intangibles, financing, safe harbors, comparability, and APAs. PE profit attribution is crucial for services and digital models. | Initial report on profit attribution to permanent establishments expected. | 4 | Digitalized and globalized economy | Targeted evaluation report on services PEs and whether services related to emerging technologies are addressed in the 2025 UN Model. Practical implementation guide to start after October 2026. | May bridge treaty work and evolving taxation of cross-border services, remote delivery, and digital value creation, especially for groups serving developing markets. | Submit evaluation report for discussion and approval, with decisions on next steps. | 5 | Tax administration and artificial intelligence | Develop a Practical Guide to Implementing AI in Tax Administrations, covering fraud detection, risk assessment, taxpayer services, dispute support, governance, legal/ethical safeguards, and risks (data/gender bias, fairness, rights). Modular workplan for varying digital maturity. | Likely to influence AI-enabled compliance programs and expected safeguards in developing countries, affecting transparency, contestability, oversight, and audit selection. | Committee to receive a detailed outline and substantially developed chapters for review. | 6 | Extractive industries taxation | Two workstreams: practical guidance on critical minerals valuation/value-addition; continued monitoring of energy transition tax developments (carbon pricing, CCUS, tax expenditures, Article 6 carbon markets). Guidance covers pricing opacity, related-party transactions, valuation, coordination, and limits of taxation. | Relevant for mining, energy transition supply chains, and minerals processing; addresses concerns about transfer pricing, export valuation, customs, and fiscal take. | First draft of Part I of critical minerals guidance scheduled for discussion; energy transition monitoring continues with ongoing reporting. | 7 | Indirect taxes (VAT/GST) | Four active workstreams: VAT in digitalized economy, VAT fraud/refund/SME compliance, cross-border VAT dispute prevention/resolution, VAT treatment of financial services (FinTech, crypto-assets). Fifth workstream on VAT regressivity/compensation under consultation. | Highly relevant for multinationals, covering platform liability, digital supplies, B2C issues, refund management, VAT controversy, financial services, and crypto-VAT — critical for revenue raising and administration modernization in developing countries. | Draft outlines for Workstreams 1-4 expected; Workstream 5 proposal to follow after scope clarification. | 8 | Dispute avoidance and resolution | Ad hoc monitoring group focusing on developments in UN tax convention negotiations and Pillar Two, consulting subcommittees, and feeding back from capacity development. Guidance on unilateral APAs assigned to transfer pricing. | Ensures Committee alignment with evolving dispute frameworks/prevention mechanisms; less about new products, more about ongoing monitoring. | Group continues monitoring and reporting; no standalone handbook or draft output for October 2026 except ongoing report. | 9 | Environmental taxation | Six priority areas: transition from fuel excises to carbon taxes, aviation emissions, land-based resources, equity impacts, international law obligations, and taxation of energy-intensive digital infrastructure. Stand-alone guidance papers planned; format TBD. | Important for energy-intensive sectors, aviation, digital infrastructure, resources, and businesses exposed to carbon pricing transition; highlights UN interest in climate, fiscal design, and sector-specific taxation. | Progress report covering research and scoping of workstreams expected. | 10 | Wealth taxation | Subcommittee proposes a Handbook on High-Net-Worth Individuals, building on the 2025 UN Wealth and Solidarity Taxes Handbook. Focus on practical guidance for developing country tax authorities, covering transparency, information exchange, data limitations, coordination, and feasibility. | May affect owner-managed groups, family businesses, shareholder disclosure, transparency, data matching, and broader policy debates on concentrated wealth taxation. | Outline of handbook to be presented for review and approval. | 11 | Tax and gender | Five concise guidance papers for developing countries: conceptual framework, tax policy and informal economy from a gender perspective, toolkit for gender in tax administration, use of tax data for gender-responsive policy, and gender in international taxation. Priority on the first conceptual paper. | May influence distributive/administrative assessment of tax rules, including indirect taxes, wealth, data, and administration; signals mainstreaming of gender in tax policy. | Outlines of five papers expected for committee comments and guidance. |
Annex 2 — Expected outputs for the 33rd Session in Geneva (late October 2026) The CRPs point to the following principal items likely to be before the Committee at the 33rd Session in Geneva expected in late October 2026: Workstream | Description | UN Model Tax Convention | First progress report, with Workstream 1 (STTR-related changes) entering discussion and with the Committee also expected to have the benefit of related outputs from the digitalized economy and transfer pricing workstreams. | UN treaty negotiation manual | First progress report, with Workstream 1 formally entering the discussion phase. | Transfer pricing | Initial report on possible Committee work on profit attribution to permanent establishments. | Digitalized and globalized economy | Evaluation report on services permanent establishments and the treatment of services related to emerging technologies in the 2025 UN Model. | Tax administration and AI | Detailed outline of the practical guide and substantially developed chapters for review and guidance. | Extractive industries | First draft of Part I of the critical minerals guidance, plus continuing monitoring updates on energy transition taxation. | Indirect taxes | Draft outlines for Workstreams 1-4, plus a refined proposal on Workstream 5 (VAT regressivity/compensation) following further consultation. | Dispute avoidance and resolution | Continued monitoring report on INC developments, Pillar Two dispute issues, subcommittee coordination and capacity-building feedback. | Environmental taxation | Progress report on research and scoping across the six proposed workstreams. | Wealth taxation | Outline of the Handbook on the Taxation of High-Net-Worth Individuals. | Tax and gender | Outlines of the five proposed guidance papers. |
| * * * * * * * * * * | | Contact Information | For additional information concerning this Alert, please contact: EY Belastingadviseurs B.V. (Netherlands) Ernst & Young Steuerberatungsgesellschaft m.b.H (Austria) Ernst & Young LLP (United Kingdom) Ernst & Young LLP (United States) | | Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor |
Document ID: 2026-0817 |
