CYIL vol. 14 (2023)

CYIL 14 (2023) THE ROLE OF INTERNATIONAL ORGANIZATIONS IN ESTABLISHING THE GLOBAL… It is likely that many developing countries face a resource gap in tax negotiations due to factors such as fewer and lesser-trained tax experts, fewer delegates, or difficulty confronting richer countries’ delegates. The ambitious agenda and compressed timeline set by the OECD and G20 exacerbate the gap and may create an additional pressure that does not produce better or quicker results. 77 But the OECD has been highlighting the support for strengthening tax their capacity, 78 alongside of UN. Importantly, while the political support remains unprecedented, this also means that such support could decrease over time, closing a window of opportunity and rendering a chance for a global tax reform virtually impossible. Finally, while cooperation on tax competition could benefit all states, eliminating competitive practices may not improve all states’ positions without redistribution of the global gain 79 and general appeals of economic or welfare gains should be questioned. 80 The countries have to consider not only the total increase of global tax revenue, but also how will this new revenue be effectively divided, why, and how is this framed in a political debate. Standardization processes can assimilate and disincentivize alternatives. A global minimum tax endorsement could render many alternative structures noncompliant in the future. 81 3.5 Resolution adopted by the UN General Assembly The language of the recent resolution of the General Assembly on 30 December 2022 82 clearly indicates a renewed will to face some of the institutional obstacles described in this article, namely “ recognizing the need to strengthen international cooperation on tax matters in a more inclusive intergovernmental forum ”. It was issued with a clear aim to promote inclusive and effective international tax cooperation through the UN. The resolution reaffirmed the general resolution on the Addis Ababa Action Agenda 83 in which Member States committed to scaling up international tax cooperation and took into account work of the most prominent bodies and initiatives, including the, the Group of 20 Ministerial Tax Symposium on Taxation and Development, 84 or the Addis Tax Initiative. 85 Most importantly, the General Assembly made two potentially ground-breaking decisions. 77 BRAUNER, Y. (2021). Serenity Now! The (Not So) Inclusive Framework and the Multilateral Instrument. Fla. Tax Rev. , 25 , 489, p. 526. 78 Group of Seven (2023). Hiroshima Leaders’ Communiqué . https://www.consilium.europa.eu/en/press/press releases/2023/05/20/g7-hiroshima-leaders-communique/ p. 4. 79 RING, D. (2022). Democracy, Sovereignty and Tax Competition: The Role of Tax Sovereignty in Shaping Tax Cooperation. Florida tax review , 9 (5). https://doi.org/10.5744/ftr.2009.1053 pp. 583, 593. 80 GOMEZ, L. C. (2020). Transcending “Tax” Sovereignty and Tax Standardization: Three Questions. The Yale journal of international law , 45 (1), 191. GÓMEZ, C., CARLOS, L., Transcending ‘Tax’ Sovereignty and Tax Standardization: Three Questions (2020). Yale Journal of International Law , Vol. 45, 2020, Available at SSRN: https://ssrn.com/abstract=4266311 p. 220. 81 Ibid. pp. 212, 222. 82 UN. (2022). Resolution adopted by the General Assembly on 30 December 2022. A/RES/77/244 . https:// documents-dds-ny.un.org/doc/UNDOC/GEN/N23/004/48/PDF/N2300448.pdf?OpenElement. 83 UN. (2015) Resolution 69/313 of 27 July 2015 on the Addis Ababa Action Agenda of the Third International Conference on Financing for Development. 84 Group of 20 Ministerial Tax Symposium on Taxation and Development, which was held in Nusa Dua, Bali, Indonesia, on 14 July 2022. 85 Initiative in fostering collective action to strengthen the capacities of developing countries for closing recognized gaps in development finance.

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