Intervention on the Protocol for Dispute Prevention and Resolution (UN Tax Convention 3rd Session)

At the 3rd session of the UN Tax Convention negotiations held 10th – 21st November 2025 in Nairobi, ISER together with the Global Alliance for Tax Justice, and the African Civil Society Working Group on the UN Tax Convention delivered a strong intervention on the Protocol for Dispute Prevention and Resolution. We called on delegates to reject the current broken Transfer Pricing system and its ‘patches,’ such as secret Advance Pricing Agreements. Instead, we demanded a fundamental shift toward Unitary Taxation and Formulary Apportionment as the only effective way to address the root causes of international tax disputes.