Comments on the “Co-Lead’s Draft Framework Convention Template” on Workstream I as of 24 October 2025.

In our view, the Framework Convention should remain focused on establishing a flexible framework for international tax cooperation. To maintain broad participation and preserve flexibility, we suggest placing all commitments in the Preamble rather than in binding provisions. We believe that the draft borrows too heavily from the UNFCCC model, whose commitmentbased structure does not fit the tax context. Unlike climate governance, tax cooperation lacks a single measurable objective, and rigid commitments could impede future developments. Accordingly, we encourage negotiators to keep the Convention open, adaptable and focused on institutional foundations.