Nations Look to Limit UN Treaty to Cross-Border Tax Disputes

Nov. 13, 2025, 9:40 PM UTC

Countries on three continents objected Thursday to a draft UN tax treaty provision over concern it would infringe on their right to choose how to resolve domestic tax disputes.

Delegates from across Europe, Asia, and Africa said a proposal from the treaty’s top negotiators appears to cover tax disputes they consider the purview of national tax authorities. They pointed to the wording of a potential provision in the treaty, as well as examples of disputes negotiators said could fall under the treaty.

“It seems like that’s a domestic issue that’s being resolved,” Gian Sandri, a Swiss representative and an official ...

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