The 31st session of the United Nations Committee of Experts on International Cooperation in Tax Matters runs from October 21 to 24, 2025 at the U.N. Office in Geneva. This committee – often called the UN Tax Committee – is a technical body of 25 independent experts that develops guidance on international tax policy and administration, with a special focus on the needs of developing countries. Committee members, appointed for a 2025–2029 term, come from diverse regions and serve in their personal capacities (they are nominated by governments but do not represent them directly). The group’s mandate is to help countries craft “stronger and forward-looking” tax policies suited to a globalized, digital economy, while preventing double taxation and curbing tax evasion and avoidance. In practice, the UN Tax Committee produces practical tools – from model tax treaty provisions to handbooks – aimed at strengthening countries’ tax systems and boosting domestic resource mobilization (raising revenue at home) for development. This week’s gathering marks the first meeting of the newly appointed membership. High on the agenda is deciding the Committee’s work program for the next four years.1
Stakeholders—including national governments, academic experts, civil society organizations, and private sector representatives—have submitted a wide array of proposals targeting the modernization of global tax norms for the Committee’s 2025–2029 work program.2 While many contributions revisit established debates such as the taxation of multinational technology corporations and the mitigation of corporate tax avoidance, others highlight emergent concerns pertaining to artificial intelligence (“AI”), health-related taxes, informal economies, and gender equity in taxation.3 This breadth of input evidences the increasing intersection of tax policy with developmental, technological, and social considerations, bearing potential implications for jurisdictions including the United States.4
From Digital Taxes to Green Levies: The Usual Suspects (and More) A significant proportion of submissions advocate for continued development of digital economy taxation, focusing on the allocation of taxing rights over corporate profits earned via online activities in countries where a company maintains users or customers but lacks physical presence.5 Of fifty-one written inputs received, thirty-eight addressed taxation of digital services or related “nexus without presence” issues.6 Many developing countries are seeking enhanced source-based taxing rights over technology multinationals, building on recent UN initiatives such as Article 12B—which targets taxation of digital services—and the conceptualization of “digital permanent establishment.”7 Relatedly, numerous stakeholders call for stricter transfer pricing regulations to curtail profit-shifting by multinational enterprises, especially through complex valuation of intangibles and intra-group transactions, which facilitate the migration of profits to low-tax jurisdictions and result in substantial revenue losses for governments.8 There is considerable support for the adoption of simplified, formulaic profit allocation methods, as opposed to the current arm’s-length principle, which is widely viewed as both administratively burdensome and susceptible to manipulation.9 Some contributors further propose the creation of safe harbors or shared databases of comparable pricing data to assist developing nations in auditing multinational activities.10
Environmental taxation has also emerged as a priority, with over a dozen submissions—including those from France and several African states—requesting comprehensive guidance on carbon pricing, the taxation of carbon credits, and the structuring of green incentives.11 Recent UN work, such as the publication of the Carbon Taxation Handbook, marks progress, yet stakeholders are seeking additional resources, including model carbon tax frameworks, assistance in navigating the European Union’s Carbon Border Adjustment Mechanism, and recommendations regarding the taxation of emissions from the aviation sector.12 These developments reflect a broader movement toward “greening” tax systems to simultaneously generate revenue and incentivize sustainable behaviors.13
Tax fairness and transparency remain central themes, with particular advocacy from U.S.-based organizations. For example, the Washington, D.C.-based FACT Coalition has urged the UN to promote public country-by-country reporting of corporate profits and tax payments, arguing that such disclosures would benefit developing countries that currently receive information only through restrictive and confidential intergovernmental exchanges.14 Presently, the United States shares multinational tax reports with only two African nations under strict secrecy provisions, thereby limiting broader access.15 The FACT Coalition contends that public reporting would eliminate costly legal barriers and facilitate oversight by tax authorities and investigative journalists, ultimately enhancing corporate accountability.16 Similarly, civil society groups from Latin America and Africa have called for the establishment of public beneficial ownership registries to expose illicit financial flows, a global transparency initiative that the United States has tentatively supported through measures such as the Corporate Transparency Act.17
While these established issues—digital taxation, corporate avoidance, environmental taxes, and transparency—already present substantial challenges, the Committee’s agenda has further expanded in response to novel stakeholder concerns. Notably, the thirty-first session’s feedback reveals the emergence of topics that have seldom been addressed in prior international tax forums. The following section examines several of these new themes and their significance, including for U.S. policy.
Taxing the Rise of AI and New Technologies Artificial Intelligence has rapidly ascended as a focal point in international tax discourse.18 Stakeholders note that AI is revolutionizing tax administration, from enhancing compliance and fraud detection to automating audit processes, and urge the UN to ensure that developing countries are not left behind in this technological transition.19 AI tools offer the potential to analyze vast datasets, automate routine tasks, and improve taxpayer services; however, resource-constrained nations often lack the technical expertise and funding necessary to implement such systems, raising concerns about a widening “tax tech” divide.20 Experts have recommended that the Committee develop guidelines or establish a dedicated task force on AI in tax administration, focusing on best practices for algorithmic every idea will make the cut; some issues might be punted to other forums (for instance, maybe the IMF or World Bank takes on informal sector taxation, or the UN’s New York process on the tax convention tackles overarching principles like global wealth taxation that were also floated).
Stakeholders are clearly thinking beyond the status quo. Whether it’s carving out a role for AI in easing tax compliance burdens, enacting excise taxes that fight diabetes and smoking, or rewriting tax rules to account for remote workers and carbon traders, the submissions urge the Committee to be forward-looking. There is also an implicit call for the UN to assert a stronger leadership role in global tax norm-setting – reflecting developing countries’ frustration with the slower, consensus-bound OECD process. The recent UN General Assembly resolution to start negotiating a Framework Convention on International Tax Cooperation heightens the stakes; the Committee’s work program might shape what eventually goes into that treaty.
For American observers, traditionally more focused on domestic tax issues or OECD initiatives, the flurry of activity at the UN is worth attention. U.S. companies and civil society alike have skin in the game: how digital profits are split, how transparent corporate finances are, and how new taxes (from carbon to AI) are designed will all affect the U.S. in time. Encouragingly, at least one U.S.-led coalition (FACT) and several U.S. academics engaged with this UN process, emphasizing that global tax fairness can advance both development and American interests by leveling playing fields. The tone of the submissions is largely cooperative – stakeholders aren’t looking to punish any one country, but to ensure all countries, especially poorer ones, have the tools to raise revenue fairly in the 21st century.
As the session unfolds, expect detailed agenda items on things like updating the UN Model Tax Convention, improving tax dispute resolution, and new guidance on tax incentives. But also expect the unexpected: discussions of things like a “Gender and Taxation” toolkit or an AI ethics charter for tax administrations could surface, which would have been unthinkable a decade ago in this arena. The breadth of stakeholder input guarantees that Committee members will at least have exposure to these diverse ideas. If they manage to translate even a portion into concrete outputs – say, a new UN handbook on health taxes or an outline for taxing remote work – it could mark a significant broadening of international tax cooperation. In the end, the 31st session’s expanded brief shows that tax isn’t a dry, isolated field anymore; it’s smack in the middle of debates on sustainable development, technology, and equity. And what happens in that realm will reverberate far beyond Geneva, reaching Washington, Lagos, Bridgetown and everywhere in between.
1.United Nations, Committee of Experts on International Cooperation in Tax Matters, Provisional Agenda of the Thirty-First Session (21–24 Oct. 2025, Geneva) (outlining session topics).
2.Id.(noting the Committee will determine its work programme for 2025–2029)
3.Id.(listing initial discussion topics including taxation and the SDGs)
4.United Nations, Financing for Sustainable Development Office, “Stakeholder Input Received for 31st Session of the U.N. Tax Committee” (Oct. 2025) (webpage listing 51 submissions from Member States and other stakeholders) at https://financing.desa.un.org/untc-31st-session-stakeholder-input
5.See UN Tax Committee, Digital Economy Taxation Inputs, supra note 1.
6.Id.
7.United Nations, Dept. of Econ. & Soc. Affairs, Article 12B: Income from Automated Digital Services, in United Nations Model Double Taxation Convention between Developed and Developing Countries: 2021 Update (2021) (introducing a new treaty provision to tax digital services). 8.Organisation for Economic Co-operation and Development (OECD), Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 (2022) (providing standards for arm’s-length pricing of intercompany transactions).
9.U.N. Committee of Experts on Int’l Tax Matters, Secretariat Note on Taxation of the Digitalized and Globalized Economy, U.N. Doc. E/C.18/2025/CRP.24 (Oct. 7, 2025), at 2–3 (observing that many developing countries advocated simplified, formulaic profit allocation methods as alternatives to the arm’s-length principle).
10.Id.at 3 (noting proposals for safe harbors and shared databases of comparables to assist developing nations’ transfer pricing enforcement)
11.United Nations, Financing for Sustainable Development Office, “Environmental Taxation” Submissions (Oct. 2025) (compiling stakeholder proposals for guidance on carbon pricing, carbon credit taxation, and green incentives).
12.United Nations Dept. of Econ. & Soc. Affairs, Carbon Taxation Handbook (2024) (a 204-page technical handbook on designing carbon taxes in developing countries, produced in cooperation with USAID).
13.Id. at 15–20 (discussing the trend toward “greening” tax systems to raise revenue while incentivizing sustainability.
14.Financial Accountability & Corporate Transparency (FACT) Coalition, Submission to the U.N. Tax Committee on Public Country-by-Country Reporting (Sept. 2025) (urging adoption of public reporting of multinationals’ tax payments).
15.Id. at 3 (noting that as of 2025 the United States shares corporate tax reports with only two African nations – Mauritius and South Africa – under strict confidentiality, limiting broader African access)
16.IId. at 4 (arguing public reporting would remove legal barriers, empower tax authorities and journalists, and improve corporate accountability in both developing countries and the U.S.
17.Corporate Transparency Act, Pub. L. No. 116-283, 134 Stat. 4604 (2021) (codified at 31 U.S.C. §§ 5331–5333) (establishing U.S. beneficial ownership disclosure requirements.
18.U.N. Committee of Experts on Int’l Tax Matters, Secretariat Note on Tax-Related Artificial Intelligence Issues, U.N. Doc. E/C.18/2025/CRP.25 (Oct. 7, 2025), at 1 (observing that Artificial Intelligence is a “powerful tool for tax administrations” but comes with significant risks and resource gaps for developing countries)
19.Id. at 2 (highlighting stakeholder concerns that developing states risk falling behind an emerging “tax tech” divide without technical and financial support for AI adoption)
20.Id. at 3 (noting proposals for global guidelines on algorithmic transparency, data privacy, and human review of AI-driven audit flags to safeguard taxpayer rights)
21.Id. at 4–5 (reporting multiple stakeholder suggestions to establish a dedicated UN tax subcommittee or task force on AI to develop best practices for AI use in tax administration)
22.Pramod Kumar Siva, Legal and Regulatory Implications of Agentic AI in Tax Administration, 118 Tax Notes Int’l 1711 (June 16, 2025) (analyzing privacy, bias, due process, and accountability challenges posed by autonomous AI in tax enforcement), available at SSRN: https://ssrn.com/abstract=5333340.
23.Id. at 1717–18 (warning that absent updated legal safeguards, the deployment of AI in tax audits may outpace the evolution of taxpayer rights protections).
24.U.N. Committee of Experts on Int’l Tax Matters, Secretariat Note on Taxation of the Digitalized and Globalized Economy, supra note 9, at 6 (noting that some submissions proposed expanding digital services taxes to cover AI-enabled services, mirroring debates on taxing highly digitalized businesses) 25.See, e.g., BEPS Monitoring Group, Stakeholder Input to UN Tax Committee Work Programme 2025–2029 (Sept. 2025), at 2–3 (advocating inclusion of digital services and possibly certain AI-based services in new taxing-rights rules); Tax Justice Network, Submission to UN Tax Committee (Sept. 2025), at 4 (proposing that digital services tax measures be considered if consensus on Pillar One falters).
26.Ryan Abbott & Bret Bogenschneider, “Should Robots Pay Taxes?”, 12 Harv. L. & Pol’y Rev. 145, 146–53 (2018) (exploring the rationale for a tax on robots or AI that displace human labor).
27.U.N. Committee of Experts on Int’l Tax Matters, Secretariat Note on Taxation of the Digitalized and Globalized Economy, supra note 9, at Annex (reflecting that even though novel ideas like an “AI tax” lack consensus, their emergence on the UN agenda underscores the urgency of adapting tax policy to technological change).
28.U.S. Dep’t of the Treasury, Press Release: United States and Five European Countries Extend Transition Agreement on Digital Services Taxes (Feb. 15, 2024) (reaffirming U.S. opposition to unilateral DSTs and extending a moratorium on DST measures pending a multilateral OECD solution).
29.I.R.S. News Release IR-2023-166 (Sept. 8, 2023) (announcing a sweeping enforcement initiative using AI to detect tax evasion patterns – including opening audits of 75 large partnerships – as part of efforts to restore fairness in the tax system.
30.Letter from Rep. Jim Jordan, Chairman, H. Comm. on the Judiciary, & Rep. Harriet Hageman to Hon. Janet L. Yellen, U.S. Treasury Secretary (Mar. 20, 2024) (inquiring into the IRS’s use of AI to monitor taxpayers’ financial data without warrants, and citing concerns of “AI-powered warrantless financial surveillance”).
31.World Health Organization, WHO Technical Manual on Tobacco Tax Policy and Administration, at 1–3 (2021) (noting that well-designed health taxes on products like tobacco, alcohol, and sugary drinks can both raise revenues and significantly reduce harmful consumption – a “double dividend”).
32.African Alliance for Health, Research and Economic Development, Stakeholder Submission on Health Taxes (Sept. 2025) (arguing that excise taxes on tobacco, alcohol, and sugary drinks could help low-income countries finance healthcare and climate adaptation, and urging the UN to develop model health tax legislation)
33.Federal Inland Revenue Service (Nigeria), Stakeholder Submission to UN Tax Committee (Sept. 2025) (calling for prioritization of a robust Subject-to-Tax Rule and noting shortcomings of the OECD’s 9% STTR scope)
34.South Centre & G-24, Press Release: Country-Level Revenue Estimates – A Comparative Analysis of UN and OECD Subject to Tax Rules for 65 Member States (July 23, 2025) (reporting that the UN’s broader STTR would yield substantially higher tax revenues for developing countries than the narrower OECD version).
