From the Margins to the Negotiations Table: How Youth Advocacy is Shaping the UN Tax Convention
By Jon Kafuko – Programs Manager, Youth for Tax Justice Network (YTJN)
If you are aged 18-35, the international tax system was not built for you. It was built for a world where wealth stayed put, where corporations had factory floors you could visit, and where the idea that a company could earn billions from users in Lagos, Nairobi, or Jakarta yet pay nothing there was science fiction.
That world is gone. But the rules remain.
Except something is shifting. Inside a United Nations conference room, within negotiations that rarely make headlines, a coalition of developing countries backed by sustained youth-led advocacy is rewriting those rules. And they are winning.
The Draft That Changed Everything
On 22 January 2026, the Co-Leads of the UN Framework Convention on International Tax Cooperation released their
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second draft treaty template
. To understand why it matters, you have to look at where the journey began.
Four months earlier, in October 2025, the first draft landed. It was historic. For the first time, a global tax treaty affirmed that if value is created in your country, you have a right to tax it. But it was also incomplete. Key provisions were missing. Binding commitments were hedged. The language too often stopped at "recognition" when action was required.
The January 2026 draft is not a revision. It is a transformation.
From Skeleton to Muscle: What Changed
On fair allocation of taxing rights, the October draft merely agreed that a right to tax existed. The January draft requires action to realise that right and explicitly mandates the renegotiation of existing tax treaties that are inconsistent with the Convention. Old, unfair deals that have bled revenues from developing countries for decades can no longer be grandfathered. They must be reopened.
On high-net-worth individuals, the October draft said States Parties agree to adopt measures "as such exchange becomes feasible." The January draft replaces "agree to adopt" with "shall develop and implement." Information sharing shifts from voluntary to mandatory. The tone changes from permission to duty.
On illicit financial flows, October's tools were optional ("as necessary"). January's tools are mandatory and must be enforced through mutual administrative assistance. The word "enforced" appears for the first time.
On harmful tax practices, October treated minimum taxes as a discretionary option, something States Parties "may include." January removes the "may" and establishes the effective taxation of activities benefiting from harmful tax practices as a required tool. The principle is locked in.
On mutual administrative assistance, October introduced the "widest measure" of cooperation but left its content vague. January enumerates six concrete forms of assistance: exchange of information, assistance in tax collection, simultaneous tax examination, tax examination abroad, service of documents, and more. An aspiration becomes a checklist.
On exchange of information, October had a placeholder: "[To come]". January delivers a fully elaborated article with foreseeable relevance standards, automatic exchange of transaction data, an anti–bank secrecy override, and explicit consideration of developing country capacities.
On capacity building, October had another placeholder. January makes it a treaty obligation: concrete efforts to respond to technical assistance demands, enhanced financial and material support, and assistance in establishing automatic information reporting systems.
This is not incremental progress. This is the difference between a framework and a foundation.
Every core commitment the Terms of Reference required from fair allocation of taxing rights, addressing HNWI evasion, mutual administrative assistance, combating illicit flows and harmful practices, exchange of information to capacity building is now present in operational detail. The skeletal architecture of October has been fleshed with muscle, sinew, and enforceable obligation.
That transformation did not happen by accident. It was the product of sustained civil society advocacy including two targeted written submissions from YTJN, in July 2025 and December 2025, and our endorsement of the joint civil society and trade unions statements issued on 11 July 2025 and 5 December 2025. Each intervention built on the last: first establishing the normative demand for binding measures, then reinforcing it with technical detail as negotiations intensified. It reflects the insistence of developing countries, particularly the Africa Group, that the Convention must be binding, equitable, and equipped with enforceable tools.
The Battle Lines Are Drawn
But drafts do not become treaties without a fight.
Within days of the January draft's release, States Parties began submitting their counter-proposals. What emerged was not a technical squabble. It was a clear, unambiguous contest between two visions of the future.
One vision, advanced by Norway and Sweden, seeks to preserve the status quo. Their proposal on Article 5 recognizes the right of market countries to tax but then carves it out. Existing treaties come first. Future protocols can override it. The obligation to act? Replaced with a recognition. The duty to renegotiate unfair treaties? Silenced.
On Article 6, Norway proposed that measures to tax high-net-worth individuals should be merely considered, with each country's domestic flexibility preserved, a recipe for inaction. On Article 7, Norway proposed that illicit financial flows should be combated only in accordance with national laws, and tools are optional. On Article 8, it suggested that harmful tax practices should be monitored, but not stopped. On Article 9, it submitted that mutual assistance should be promoted, not delivered.
This is not a defence of sovereignty. It is a defence of leakage, the organised, legalised drainage of public revenues from the countries that need them most.
The other vision, carried by the Africa Group, takes the Co-Lead's draft and fortifies it.
Their Article 5 does not merely recognise the right to tax; it mandates that allocation reflect "real economic contribution." It names users and data as legitimate nexus factors. It explicitly prohibits denying taxing rights solely for lack of physical presence. And it requires that existing treaties be renegotiated where they conflict with these principles. No carve-outs, no indefinite grandfathering.
Their Article 8 retains the full binding toolbox and adds a minimum effective tax rate for economic activities that benefit from harmful tax practices. Not a suggestion. An obligation.
Their Article 9 preserves the "widest measure" of mutual administrative assistance, enumerates six concrete forms of cooperation that are simultaneous tax examinations, assistance in collection, service of documents and mandates the elimination of administrative barriers, not merely their identification.
India occupies a middle ground: progressive on nexus and the digital economy, but cautious on binding tools and silent on the minimum tax. Its Article 9 retains mandatory assistance language but defers every concrete measure to future protocols. Good intentions, postponed.
What Does This Mean for Youth?
This is not abstract diplomacy. The difference between these visions is the difference between a clinic that stays open and one that closes. Between a classroom with textbooks and one without. Between a generation that inherits the means to adapt to climate change and one that inherits only the debt burden.
In April 2025, UNCTAD Secretary-General Rebeca Grynspan stated that “Africa alone loses nearly 100 billion dollars every year to IFFs”, which is twice the amount received in foreign aid and foreign direct investment. That is not an accident. It is the intended outcome of a tax system designed by and for those who profit from its loopholes.
The Africa Group's proposals would begin to close those loopholes. Their Article 5 would allow African countries to tax the digital platforms that extract user data and advertising revenue from their young populations, no local office required. Their Article 8 would establish a minimum tax floor, ending the race to the bottom where countries compete to offer the lowest rates to multinationals. Their Article 9 would give tax authorities the tools they need to follow the money across borders.
For the 1.8 billion young people worldwide, this is what tax justice looks like. Not a technical adjustment. A redistribution of power.
YTJN's Role: From Advocacy to Architecture
This outcome did not materialise by chance. The Africa Group's legal commentary accompanying its Article 5 submission is not the work of diplomats alone. It reflects years of civil society capacity-building, technical assistance, and strategic partnership.
YTJN's written submissions to the Inter-governmental Negotiating Committee was explicit: we demanded strong, binding measures to reallocate taxing rights to developing countries, curb cross-border tax abuse, and ensure tax revenues support sustainable development. We signed the joint civil society and trade unions submissions on the Co-Lead's drafts. We showed up, in writing, with concrete text and principled argument.
Those submissions did not disappear into a UN archive. Its language, "binding measures," "reallocation of taxing rights," "curbing harmful tax practices" is now the language of the Africa Group's negotiating position. The treaty renegotiation clause in their Article 5? That is our demand, operationalised. The minimum tax in their Article 8? That is our advocacy, translated into treaty text. The full-spectrum mutual assistance in their Article 9? That is the tool we identified as essential to detecting and preventing illicit flows.
We did not merely support the Convention. We supplied the architecture.
The Fight Is Not Over
The January 2026 draft proved that transformation is possible. It took a skeletal framework and built a foundation. It took the Terms of Reference and turned them into operational treaty language. It replaced "may" with "shall," recognition with obligation, aspiration with enforcement.
But that foundation is now under assault. Norway's proposals have not been withdrawn. The carve-outs, the qualifiers, the permissive language all remain on the table. The coming months will determine whether the final Convention reflects the Africa Group's ambitious, youth-centred vision or the diluted, status-quo-preserving alternative.
Some delegations will argue that binding measures are unrealistic, that minimum taxes infringe sovereignty, that treaty renegotiation is too disruptive. They will dress these arguments in the language of pragmatism and consensus.
We recognise them for what they are: defences of a system that extracts trillions from public budgets and transfers them to private accounts; that starves young people of the resources we need to survive and thrive; that treats the Global South as a source of raw materials and a destination for dirty money, never as an equal partner in rule-making.
We are not persuaded. And we are not silent.
What You Can Do
The Framework Convention will not be saved by diplomats alone. It will be saved by political will and political will is built by movements.
● Share this blog. Break down the wall between these negotiations and the young people who have the most at stake.
● Amplify the Africa Group's proposals. Their position is our position. Call it what it is: leadership, not compromise.
● Hold your government accountable. If your country is among those weakening the text, demand to know why. If it is absent from the room, demand to know why.
The youth climate movement taught the world that intergenerational justice is not a niche concern, it is the defining question of our era. Tax justice is no different. The resources to fund a liveable planet already exist. They are simply in the wrong hands.
This treaty is our chance to move them.
The January draft proved progress is possible. Now we must defend it.
Youth can wait no longer. Neither should the world.
To engage with youth-led advocacy on a United Nations Framework Convention on International Tax Cooperation and join our journey, feel free to reach out to us via: info@ytjn.org.
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