An update on international tax law from the United Nations Tax Committee 32nd session

27 April 2026

Last updated: 28 April 2026

Katie Close CA
Director of Tax, ICAS

The United Nations (UN) Tax Committee set out ambitious work plans at its 32nd session held in New York in March. These developments will shape international tax policy, guidance and cooperation in the coming years.

The UN Tax Committee is a subsidiary body of the UN Economic and Social Council. It shapes policy and practical guidance in international tax cooperation. It’s a globally recognised and respected organisation that provides recommendations for governments, policy makers and tax administrations. It also focuses on emerging international tax issues and has specialist subcommittees to look at each area in detail.

At the 31st session in October 2025, the Committee launched its 2025-2029 agenda, with 11 workstreams. The latest session, held in New York, builds on that. It has set out some ambitious workplans across these areas including transfer pricing, digitalised economy, tax administration and AI and wealth tax, and more.

Watch the the joint closing statement from the session.

Transfer Pricing

This subcommittee will focus on attributing profits to permanent establishments. It will also consider other relevant topics such as an industry guide for the information and communications technology sector, and guidance on unilateral Advance Pricing Agreements.

It plans to present an initial report on the attribution of profits to permanent establishments at the next Committee session in October 2026. This will outline options and areas for further guidance.

The Subcommittee will update the 2021 United Nations Transfer Pricing Manual to take account of new business models. Updates will be made to chapter 5 (intragroup services), chapter 6 (intangibles), and chapter 9 (intragroup financial transactions).

UN Model Tax Convention

The Committee approved a substantial revision of the UN Model Tax Convention (Model) in 2025. However, several issues still need attention.

The Subcommittee will now address these issues. This includes the Subject-to-Tax Rule, source rules, and the attribution of profits to permanent establishments.

It will also consider the issues related to Article 7 and its commentary, as well as the permanent establishment concept and nexus rules. This includes the consideration of non-physical presence and new business models.

Digitalised and globalised economy

The Subcommittee will produce an evaluation report on the treatment of services permanent establishment and services related to emerging technologies in the Model.

Emerging technologies will include artificial intelligence, machine learning and the internet of things.

It will also produce a practical implementation guide to help countries apply the Model’s services related provisions.

Tax administration and AI

This Subcommittee will prepare a draft Practical Guide to Implementing Artificial Intelligence for Tax Administrations. The guide will cover matters such as fraud detection, risk assessment and mitigation, taxpayer service, governance frameworks and safeguards. That will include data and gender biases, and will promote integrity, as well as data confidentiality. The draft guide is due no later than October 2027.

Tax and gender

To achieve gender equality in taxation, the Subcommittee is focused on policy and administrative actions.

Its workplan includes five guidance papers focused on developing countries:

Overview of taxation and gender: conceptual framework, evidence and resources
Tax policy and the informal economy from a gender perspective
A toolkit for incorporating a gender perspective into the work of the tax administration
Tax data and gender for adequate policy design
Gender and international taxation

Wealth Tax

Due to rising inequality in many countries, the Committee agreed to pursue work on wealth taxation.

The Subcommittee will develop draft guidance on policy and administrative issues in the design and implementation of wealth taxation, including the taxation of high net worth individuals. This work builds on the United Nations Handbook on Wealth and Solidarity Taxes, approved by the Committee in 2025.