A coalition of feminist and tax justice civil society organisations has called on the United Nations to adopt a bold, rights-based and gender-responsive approach in the development of the proposed UN Framework Convention on International Tax Cooperation.
In a joint submission addressed to Mr. Ramy Youseff, Chair of the Intergovernmental Negotiating Committee (INC), and Mr. Daniel Nuer, Co-Lead of Workstream I, the organisations argue that the current draft template released on 24 October 2025 lacks ambition and fails to adequately address deep structural inequalities embedded in the global tax system.
The submission was coordinated by the African Women’s Development and Communication Network (FEMNET) in collaboration with members of the Tax and Gender Working Group convened by the Global Alliance for Tax Justice (GATJ). Signatories include Tax Justice Network Africa (TJNA), ActionAid International, Akina Mama wa Afrika, ISODEC Ghana, Tanzania Youth Feminist Movement, INESC Brazil, and Red de Género y Comércio (Latin America).
Read the Submissions below…
For the kind attention of: Mr. Ramy Youseff, Chair of the Intergovernmental Negotiating Committee to draft a United Nations Framework Convention on International Tax Cooperation and two early protocols (INC) and Mr. Daniel Nuer, Co-Lead of Workstream I.
Cc: Permanent Representatives and Observers to the UN in New York 5th December 2025 Subject: Joint Feminist civil society submission regarding the Co-Lead’s Draft Framework Convention Template, published 24 October 2025.
Please find below a submission by the African Women’s Development and Communication Network(FEMNET), Tax and Gender Working Group convened by Global Alliance for Tax Justice(GATJ), Tax Justice Network Africa(TJNA), Action Aid International, Akina Mama wa Afrika (AMwA), Integrated Social Development Center (ISODEC) Ghana, Tanzania Youth Feminist Movement, INESC Brazil and Red de Género y Comércio, America Latina.
This submission accompanies and reinforces two other key documents submitted by the Global Alliance for Tax Justice (GATJ) Joint Response to the Co-Leads Draft Template:
https://globaltaxjustice.org/news/co leads-draft-template-response/ A comprehensive Catalogue of Proposals for Articles in the UN Framework Convention on International Tax Cooperation: https://globaltaxjustice.org/news/un-tax-convention-catalogue/ and The African CSOs submission by Tax Justice Network Africa (TJNA).
Abstract
This submission advances a feminist, rights-based approach to the development of the UN Framework Convention on International Tax Cooperation. Global tax rules must confront and transform structural inequalities that determine who creates value, who benefits from it and who bears the burdens of taxation.
A feminist rights-based approach is essential for designing an international tax system that centers substantive gender equality and redistributes resources to challenge entrenched power imbalances. We provide recommendations on key provisions in the draft text, especially Articles 4, 5, 6, and 10.
Across these articles,
We highlight where stronger commitments, clear definitions and more equitable mechanisms are necessary to advance tax justice and uphold states’ human rights obligations. A feminist rights-based approach clarifies that tax policy is not gender neutral; it is a site where colonial, patriarchal and economic power is negotiated and reproduced. Through this lens, the UNTC can serve as a transformative instrument for advancing tax and gender equality by correcting historic imbalances embedded in global tax rules.
Progressive international tax systems can mobilise and redistribute resources more fairly, shifting wealth from multinational corporations and global elites towards investments that reduce women’s unpaid care burdens, strengthen public services, expand bodily autonomy and secure economic dignity and decent work for all.
This approach also aligns with existing commitments under CEDAW, the Beijing Platform for Action, the Sustainable Development Goals and most recently the Compromiso de Sevilla, which call for dismantling discriminatory economic structures and ensuring fiscal policy advances substantive gender equality rather than undermining it.
Summary of Recommendations Overall Comments
The template lacks ambition, substantive direction and fails to deliver on the mandate as outlined in the Terms of Reference (ToR), including the overall objective of establishing “an inclusive, fair, transparent, efficient, equitable and effective international tax system for sustainable development”.
Its omissions are particularly concerning considering the urgent need for a global tax architecture that advances substantive gender equality and addresses structural injustices that disproportionately impact women and girls in all their diversities. In this context, we provide key recommendations on the relevant articles in the sections below to ensure that the UN Tax Framework Convention delivers on its mandate and advances tax justice, gender equality and sustainable development goals.
Article 4 on the Scope and Fair Allocation of Taxing Rights Multinational corporations continue to avoid and evade taxes under the current international rules, resulting in countries losing an estimated US$1Billion per day, funds that could support public services, healthcare systems, and gender equality. These losses have profoundly gendered impacts, as governments often compensate by raising consumption taxes and overtaxing small businesses, many of which are women-owned, thereby deepening women’s economic insecurity. At the same time, tax incentives disproportionately benefit men because wealth and high-value assets remain largely concentrated in male-dominated sectors.
As governments compete for investment by lowering taxes and deregulating markets, they weaken labour and environmental protections, fuel austerity, and increase reliance on indirect taxes that further restrict women’s access to essential goods and limit their financial autonomy.
We welcome the recognition of source countries’ rights to tax income from business activities within their jurisdiction, but the article still contains major gaps. Its vague references to “business activities” and reliance on the concept of value creation continue to favour residence jurisdictions, predominantly in the Global North.
From a feminist rights-based perspective, the notion of “value” must be reconsidered, as current global tax rules privilege intangible assets and capital while devaluing labour, natural resources, and social reproduction, areas where women’s economic contributions are most concentrated. We thus recommend that:
- The entire concept of value creation should be deleted as it creates ambiguity and provides a loophole that multinational corporations can exploit for tax avoidance.
- Fair allocation of taxing rights should be based on economic presence with taxation grounded in source-based principles as opposed to residence-based rules that disproportionately benefit Global North jurisdictions.
- A specific Article on equitable taxation of multinational enterprises, which introduces a transition to unitary taxation with formulary apportionment should be included and should reflect where economic activity and therefore real value is generated. Without this, the UNTC risks replicating the same injustices embedded in OECD-led processes.
Article 5 on High Net-worth Individuals Global inequality remains extreme: the poorest 50% of people own just 2% of global wealth, while the richest 10% hold 76%. Across most regions, especially Latin America, Sub-Saharan Africa, and MENA, the bottom half earns less than 15% of total income, whereas the top 10% capture over 40–60%. Women’s economic position also reflects this inequality, as their share of global labour income has risen only marginally, from about 30% in 1990 to less than 35% today.
1 Article 5 remains ambiguous in its scope and intent. While it outlines measures to detect and thwart tax avoidance and evasion by high-net-worth individuals, the Article does not provide sufficient clarity on the mechanisms for effective taxation, nor does it establish explicit guidance on the treatment of HNWI income or corporate taxation. We thus recommend that the convention;
- Clearly defines parties’ obligations in relation to taxation of high-net-worth individuals, specifies the scope of income and assets subject to disclosure and taxation and an explicit inclusion of wealth taxes.
- Ensures the effective taxation of HNWI’s wealth, including consideration of levying a higher direct tax on the wealthy and redistributing resources, would be useful in raising funds to be directed towards critical sectors such as education, healthcare, and social infrastructure. Taxation should have an international component to ensure fairness as opposed to being fully residence based. Article 6 Mutual Administrative Assistance We recommend that;
- Article 6 should allow for the transfer of technology at no cost towards Global South countries that are particularly the least developed. The application of special and differential treatment and the imposition of grace periods for Global South countries is critical.
- Introduce an Article in the Convention that establishes a UN Global Asset Register (GAR) that links all types of assets, companies, and other legal vehicles used to own assets, to their beneficial owners.
Introduce specific Articles on key transparency mechanisms, including Public Country-by-Country Reporting (CBCR), AIE and BO Transparency based on commonly agreed standards and multilateral solutions.
- Article 6 should also include a differentiation between developed countries, which are required to introduce the reporting requirements within two years 1World Inequality Report 2022: https://wir2022.wid.world/www-site/uploads/2022/03/0098 21_WIL_RIM_EXECUTIVE_SUMMARY.pdf after the entry into force of the Convention, and developing countries, which are not given a specific deadline but will immediately be privy to reports shared by developed countries to reflect global south realities. Article 9 on Sustainable Development Tax and Gender Although tax systems are often described as gender-neutral, they are not; by ignoring gendered economic realities such as income inequality and unpaid care work, they reinforce rather than reduce disparities. The current global tax system fails because it is rooted in colonial, patriarchal, imperial and neoliberal structures that concentrate wealth and power while marginalising women, Indigenous peoples, people of African descent, and other oppressed groups.
Tax must therefore not be treated as a purely technical matter—it is inherently political and fundamentally about justice, rights, and equality. Previously, governments have committed to enforce gender responsive taxation within their jurisdictions. These commitments are laid out in among others; the Convention on Elimination of Discrimination against Women and Girls, which in Articles 2-3 and 11-15 obliges states to remove discriminatory tax provisions, assess gender impacts of tax measures, ensure equal access to tax benefits/credits, and structure revenue in ways that advance substantive equality. This is further emphasised in the Compromiso de Sevilla, in which, under para 27, states committed to advancing gender responsive taxation.
We acknowledge that these commitments remain unrealised because the existing global tax architecture constrains the fiscal sovereignty of countries, especially those in the global south. This limits their ability to design progressive and gender responsive tax systems. As a result, states rely on regressive taxes and spending cuts that disproportionately harm women and undermine gender equality goals. We thus recommend that the convention;
- Includes a commitment to ensure that fiscal systems are fully in line with the UN Member States’ existing obligations to progressively realise human rights and gender equality to the maximum of their available resources. This should include explicit references to the goal of reducing gender inequality within and among countries and to publicly financing gender-responsive public services.
- Includes a clear commitment to ensuring that tax systems and international tax rules actively promote gender equality through explicit gender-sensitive language, recognition of the differentiated impacts of tax policies on women and men, and the elimination of gender bias in tax legislation and administration. Mandates countries to maintain transparency and accountability systems towards commitments on gender equality and tax through the collection of gender disaggregated data and the systematic use of human rights and gender impact assessments to evaluate the effects of tax policies.
- The Article on Sustainable Development should create an obligation on each Party to report regularly on its performance in relation to commitments under the Article, in accordance with the different needs, priorities and capacities of Parties (ToR para 9(a)). The future Conference of the Parties should also perform an overall review of the implementation of this Article as a standing agenda item during each meeting.
- The Parties to this Convention shall establish a standard to assess the gender responsiveness of this Convention and its Protocols, as a contribution towards the fulfillment of existing UN obligations, commitments and targets, and to ensure the full realization of the rights of women and girls and gender minorities, while addressing their intersectional inequalities. For this purpose, and while bearing in mind the different needs, priorities and capacities of Parties, including developing countries, the Conference of the Parties shall develop a standard, including specific gender transformative methodologies and tools for designing, monitoring and evaluating the Convention and its Protocols. Furthermore, the standard will be accompanied by a roadmap for implementation and regular reviews by the Conference of the Parties, beginning no later than 2030.
- Through the standard, the Parties shall be required to maintain transparency and accountability systems towards their commitments and obligations on gender equality and tax, investing in the production of gender-disaggregated data to inform measures to address existing and intersecting inequalities, gender-differentiated needs and gender discrimination within tax systems. This shall include the effects that a Party’s tax system has on gender equality within its own jurisdiction, as well as any potential spill-over effects on the tax systems of other Parties, particularly developing countries.
- As an integrated part of the roadmap for implementation, the Parties shall carry out periodical national assessments of the implementation of this standard, taking into account the commitments of non-retrogression of rights and maximum available resources to ensure substantive gender equality, including recognition of the unpaid or underpaid care work. Article 10: Prevention and Resolution of Tax Disputes We recommend that;
- The article clarifies the role of Article 10 in relation to Article 20 and the 2nd Protocol. Avoid introducing dispute resolution obligations without clarifying the legal basis and the scope. The focus of the UN Tax Convention would be to resolve disputes arising under the Convention itself, which will be addressed under Article 20.
Thus, the added value of Article 10 is questionable. A truly feminist tax system is not just about removing explicit discrimination; it is about designing policies that actively close gender gaps. Tax justice is gender justice. Let us seize this opportunity to build an equitable tax system that truly serves all.
