The ongoing third session of the Intergovernmental Negotiating Committee (INC), held in Nairobi from 10 to 19 November 2025, is reshaping how countries cooperate on taxation. As UN Tax Talks continue, African countries are participating more assertively than ever, influencing the proposed UN Framework Convention on International Tax Cooperation. This moment is a turning point for global tax governance and for Africa’s long-term revenue strategies.
Why These Negotiations Matter for Africa
African countries have approached this round of negotiations with unprecedented unity and preparation. With close to 90% participation from the continent, the region is no longer a bystander in shaping global norms.
For economies struggling with low tax-to-GDP ratios, capital flight and an expanding digital marketplace, the UN Tax Talks represent a rare opportunity to embed African needs into the global tax system.
Core Issues Being Negotiated
Several critical themes are under discussion as the INC session advances.
Structuring the Framework Convention at the Heart of the UN Tax Talks
Delegates are debating the obligations countries should adopt—such as transparency measures, exchange of information and minimum standards. These decisions will shape how global tax rules operate for decades.
Digital Services and Cross-Border Income in the UN Tax Talks
A major focus is how countries should tax income generated through digital or cross-border services. This is especially relevant for African economies that are rapidly expanding their digital sectors.
Dispute Prevention and Resolution in the UN Tax Talks
African delegations are calling for more accessible, equitable and efficient mechanisms to prevent and resolve tax disputes. Confidentiality and information management are also central discussion points.
Each of these issues connects directly to Africa’s long-term fiscal ambitions.
How African Countries Are Influencing the UN Tax Talks
A notable development in Nairobi is Africa’s more assertive role. Delegations—often supported by ATAF’s coordinated technical input—are advancing proposals rooted in the continent’s realities rather than waiting for external drafts. Priorities include:
- ensuring fair allocation of taxing rights
- aligning international rules with sustainable development goals
- integrating digital tools into tax administration
- strengthening measures against illicit financial flows
- maintaining a balance between investment competitiveness and fairness
This coordinated approach is strengthening Africa’s presence in the UN Tax Talks.
The Challenge of Implementation After Nairobi
Even with strong outcomes, implementation will determine whether the Convention delivers real benefits. African tax administrations will have to:
- invest in digital systems, audits and data analytics
- strengthen asset registries and beneficial ownership frameworks
- update legal frameworks on cross-border taxation
- build taxpayer trust to improve compliance
The UN Tax Talks can provide the structure, but national reform will unlock the actual gains.
A Closer Look at North Africa’s Position
North African countries—Egypt, Algeria, Morocco and Tunisia—have strong incentives to follow the negotiations closely. Their economies are deeply linked to global trade, digital services and diaspora remittances.
For these countries, the Convention could help:
- improve transparency over offshore wealth
- modernise cross-border tax rules
- strengthen dispute-resolution mechanisms
- ensure fairer taxation of digital exports
North Africa is well-placed to benefit quickly once final provisions are adopted.
What Observers Are Watching as Negotiations Continue
Several open issues remain critical as the INC session progresses:
- Will transparency and beneficial-ownership requirements remain strong?
- How clearly will taxing rights over digital and remote services be defined?
- Will dispute mechanisms be designed with developing countries in mind?
- How will regional bodies align their own tax frameworks with the Convention?
The coming days will reveal how effectively African priorities are reflected in the consolidated text.
The Bottom Line: A Significant Opportunity for Africa
The UN Tax Talks in Nairobi represent a major step forward in global tax diplomacy. Africa’s active participation marks a shift from merely applying global rules to helping design them.
If African negotiators succeed in securing balanced provisions—and if countries follow through with national reforms—the continent stands to gain:
- improved domestic revenue
- reduced reliance on external financing
- modern, transparent tax systems
- stronger fiscal autonomy
Africa is shaping a new era of international tax cooperation, with the decisions made in Nairobi likely to influence the continent’s fiscal future for many years.
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