This is the 1st episode of Impôt et Justice sociale in English! Idriss Linge takes you inside the fifth negotiating session on the United Nations Framework Convention on International Tax Cooperation, held in New York from 3 to 13 August 2026. Using official recordings of the session, the episode follows three decisive questions: who has the right to tax a multinational’s profits, what happens to the tax treaties already signed, and who settles it when two governments disagree. On Article 5, the draft recognises the right to tax where markets, users or data are located, even without a physical presence. The United Kingdom and France push back, while the African Group, speaking through Zambia, and Kenya still find the text too weak. On Article 21, the African Group fears that updating old treaties could be put off indefinitely: a duty to negotiate, the University of Nairobi points out, is not a duty to agree.

Regarding the discussions on dispute resolution, Ghana, on behalf of the African Group, draws a red line on arbitration, a costly procedure that pits small tax administrations against the teams of tax accountants that multinationals can deploy, and one the International Chamber of Commerce supports. One fault line runs through all these debates: how far should the convention bind countries right now?

Ahead of the next session, due in Nairobi at the end of November 2026, the episode flags three things to watch: whether ‘and’ becomes ‘or’ in Article 5, whether the on-request trigger survives in Article 21, and whether arbitration becomes an option each state must first accept.

To learn more about the negotiations towards fairer tax cooperation, click on this link.