4 Apr 2025
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At its March 2025 meeting, the ICC Taxation Commission tackled global tax challenges, including UN reforms, digital economy rules, and OECD compliance amid rising geopolitical tensions. The Commission stressed inclusive dialogue and business input to help shape a clear, practical international tax framework.
UN-led tax reforms, digital economy protocols, and OECD challenges headline a pivotal Commission meeting. The ICC Taxation Commission’s March 2025 meeting convened at a critical moment for global tax policy. Against the backdrop of growing geopolitical instability and fragmentation in international trade, ICC members gathered to address urgent developments in global taxation frameworks, digital economy protocols, and regional policy shifts.
Trade Turbulence and Strategic Advocacy
Opening the session, Andrew Wilson (ICC Vice-Secretary General) and Valerie Picard (ICC Head of Trade) addressed a key concern: the erosion of multilateralism driven by unilateral trade measures, particularly from the U.S. While the core trade stance hasn’t dramatically changed, the implementation is now more aggressive and less internally contested. This “louder, more coordinated” approach risks hardening global divides and undermining established multilateral institutions. In response, the ICC is stepping up its advocacy efforts, producing foundational papers—such as on VAT—that provide clarity and are being actively used by member states in their policy dialogues.
UN Tax Convention: Inclusive, But Complex
Michael Braun (Germany UN Mission) shared an update on the UN process to establish a framework convention for international tax cooperation. Spurred by growing calls from developing nations, the convention aims to rebalance rule-making power and build a more inclusive and equitable tax framework. The process now moves into a drafting phase following the adoption of the Terms of Reference in 2024, which laid out three pillars: a framework convention, a protocol on digital services taxation, and another on dispute prevention. The structure includes three workstreams, co-led by representatives from the Global South. While the Terms of Reference do not formally embed stakeholder engagement, ICC is pushing for structured business input, emphasizing that private sector expertise is crucial to ensuring practical, implementable rules.
The OECD Debate: Pillar Two and Compliance Burdens
In parallel, the OECD’s Pillar Two implementation sparked intense debate. Business representatives flagged compliance costs, especially for low-risk jurisdictions, and questioned the added value of full model rules in such cases. ICC presented a proposal for permanent safe harbors based on country-level data and simplified reporting, aimed at lowering compliance costs while maintaining tax integrity. Although the idea gained some support, concerns about erosion of tax bases persist among certain jurisdictions. ICC called for urgent high-level government engagement to maintain momentum and promote a practical, stable system.
Regional Insights and Diverging Trajectories
Regional sessions showcased both alignment and divergence. In the Asia-Pacific, the Belt and Road Initiative tax platform highlighted progress in digitalization and capacity building. Meanwhile, the EU is focusing on simplification and competitiveness, with the European Commission reviewing directives for redundancy in light of Pillar Two’s global uptake. Africa, represented by Thulani Shongwe (ATAF), spotlighted VAT collection challenges and a growing push for regional cohesion on core tax policy positions, backed by the African Union. The U.S. position remains a wildcard. With the administration opposing some OECD rules and broader concerns about extraterritoriality, participants expressed concern over the stability of the current multilateral tax order.
Beyond Structure: Substance in Focus
As the UN tax convention process advances, the spotlight is shifting from structure to substance. Key issues include the scope of Article 12 on digital services, the potential for simplified allocation systems, and whether the dispute protocol will embrace binding arbitration or remain limited to prevention mechanisms. The ICC emphasized the need for clarity to avoid conflicting obligations and ensure smooth integration with existing treaties.
Ongoing Projects and What’s Next
The Commission’s working groups reported on ongoing initiatives including:
• Foreign subsidy regulations
• VAT treatment for cross-border telework
• Sustainability-linked tax policies
• The interaction between investment treaties and tax rules
All underscored the same themes: simplicity, coherence, and coordination. Fragmented rules risk undermining both taxpayer certainty and government revenue collection.
Looking ahead, ICC will play a key role in the UN’s Financing for Development Forum (FfD4) in Seville, where business engagement will address the impact of tax on development, investment, and sustainability. A new economic impact study on digital service taxation is also in the works, and ICC continues to push for inclusive dialogue as UN protocols are developed.
“The global tax landscape is being redefined,” one participant noted, “and ICC must be both a stabilizer and a shaper of that future.”