For the first time, a draft multilateral tax treaty negotiated at the United Nations has an article with the heading "High-net worth individuals." It sits in the Co-Lead's Zero Draft of the UN Framework Convention on International Tax Cooperation, document A/AC.298/CRP.32, dated 21 July 2026. As its name says, it is the co-lead's first full draft of the convention, published for the negotiators together with two draft protocols.
Headlines about "the UN coming for the rich" write themselves. The text is more modest than the headlines, and more durable than its critics hope. For internationally mobile people with real wealth, the useful response is neither alarm nor dismissal. It is to read what the draft actually says, see where it fits in what already exists, and draw the one conclusion that follows from both.
How the UN got here
The process has a clear legal basis. The General Assembly adopted terms of reference for the convention in resolution 79/235, published as document A/AC.298/2 of 16 January 2025. Paragraph 10 lists the commitments the convention "should" contain. Item (b) reads: "Addressing tax evasion and avoidance by high-net worth individuals and ensuring their effective taxation in relevant Member States."
The same document fixes the timetable. A negotiating committee meets in 2025, 2026 and 2027, at least three sessions a year, and is to submit the final text of the convention and two early protocols to the General Assembly in the first quarter of its 82nd session. The committee's sixth session is scheduled for 30 November to 10 December 2026.
Wealthy individuals were also on the shortlist for a separate protocol. Paragraph 16 of the terms of reference named four candidate topics for the second early protocol, one of them being high-net-worth individuals. The topic that went ahead was disputes: the draft Second Protocol of 20 July 2026 is a protocol "on the Prevention and Resolution of Tax Disputes", and the draft First Protocol covers income from cross-border services. Wealthy individuals are dealt with in the convention itself, not in a protocol with operative rules of its own.
What Article 6 says
Article 6 of the zero draft has three paragraphs. In full:
- "States Parties shall cooperate to enhance measures to detect, deter and prevent tax avoidance and evasion by high‑net‑worth individuals."
- "The States Parties shall share general information regarding structures and techniques used by high-net worth individuals to avoid and evade taxes."
- "The States Parties shall explore coordinated approaches to ensuring effective taxation of high- net worth individuals while respecting each State Party's sovereign right to determine the design, structure and level of taxation within its national tax system."
Read slowly, the article does three things. It commits states to cooperate against avoidance and evasion. It commits them to share general information about structures and techniques, which is information about methods, not about named people. And it commits them to explore coordinated approaches to "effective taxation", while saying in the same sentence that each state keeps the right to decide the design, structure and level of its own taxes.
What the article does not do matters as much. It does not create a wealth tax. It does not set a minimum rate on anyone's income or assets. It does not define a high-net-worth individual. It does not oblige any country that has no income tax, or no capital gains tax, to introduce one. The third paragraph protects exactly that choice.
Where the teeth would be: information
The operative force of the draft is elsewhere, in the articles on administrative assistance. Article 10 lists forms of cooperation the states parties are to promote: exchange of information, assistance in tax collection, simultaneous examinations, tax examinations abroad and service of documents, each "under procedures to be specified in future protocols or other instruments".
Article 11, on exchange of information, is the clause to watch. It is printed entirely in square brackets, which in treaty drafting means the text is not agreed. Even the threshold is open: information that "[may be][is foreseeably]" relevant. Two features of the bracketed text stand out for mobile wealth:
- Paragraph 1(a) refers to information on "types of assets and instruments" that states parties identify in future as "providing opportunities to circumvent then-existing automatic exchange of information mechanisms".
- Paragraph 5 provides that a state may not refuse to supply information "solely because the information is held by a bank, other financial institution, nominee or person acting in an agency or a fiduciary capacity or because it relates to ownership interests in a person."
Paragraph 5 is aimed at secrecy. Paragraph 1(a) is the more forward-looking one. It describes a convention that would keep looking for the gaps in automatic exchange and close them by later agreement.
How this fits with what already exists
Automatic exchange of financial account information already runs through the OECD's Common Reporting Standard, and its amended version applies from 1 January 2027 in the jurisdictions that have adopted it. Separate guides cover how Singapore wrote the amended CRS into its regulations and how the Crypto-Asset Reporting Framework reaches the UAE, Singapore and Hong Kong from 2027.
Against that background, the UN draft is not the start of transparency. It is a second forum for it, organised differently. Article 25 of the zero draft says plainly: "No reservations may be made to this Convention." Article 26 provides that it enters into force after a number of ratifications that is still a blank in square brackets. A framework convention of this kind sets commitments and an institution, a Conference of the States Parties under Article 13, and leaves detailed rules to protocols that states join separately.
The practical timeline follows from the terms of reference. If the committee meets its deadline, the General Assembly would consider the text in the first quarter of its 82nd session. Ratifications, entry into force and any protocol on information would come after that. Nothing in the zero draft changes anyone's tax position today.
The argument: plan on the assumption that information travels
So what should an internationally mobile person with significant wealth take from a draft that binds nobody yet? The position The Brief takes is this: the draft changes the direction of risk more than the size of it.
The direction is visible in the documents. The General Assembly's own terms of reference put the effective taxation of high-net-worth individuals on the list of commitments. The zero draft turns that into an obligation to cooperate and share knowledge of structures, and its bracketed information article describes a process for closing gaps in automatic exchange as they are found. The amended CRS and CARF are already written into law in jurisdictions such as Singapore for 2027. Each of these steps assumes that tax administrations will see more, not less.
The size of the risk is a different matter, and the text is reassuring on one point that matters most to people who move. Article 6(3) protects each state's "sovereign right to determine the design, structure and level of taxation." A country that chooses to tax lightly, or territorially, or not at all on certain income keeps that right under the draft. Moving your residence to such a country, genuinely, with the days, the home and the life to match, is not avoidance or evasion in the sense the draft addresses. It is the use of a choice the draft expressly preserves.
The planning that is exposed is the planning that depends on information not travelling: accounts nobody reports, nominees nobody looks through, residence claimed in one country while the life is lived in another. That kind of arrangement was already under pressure from the CRS. The UN text adds a forum whose stated purpose includes finding what the existing mechanisms miss.
Two further points follow. First, a low tax rate held by policy can change; The Brief made that case in Zero Tax Is Not Zero Cost, and the draft's protection of national choice protects a government's right to change its mind as much as its right to keep low rates. Second, for some people the main tax relationship is not with their country of residence at all. Citizens of the United States, which taxes on citizenship (see how the US taxes its citizens abroad), carry their home tax system with them wherever they live, so for them the choice of residence is only half of the picture.
What to watch, and what not to
The next documents worth reading are the revised drafts for the sixth session and that session's report. The questions that matter for mobile wealth are concrete:
- whether Article 11 leaves its brackets, and with which threshold, "may be" or "foreseeably" relevant;
- whether paragraph 1(a) on assets that escape automatic exchange survives;
- whether Article 6 gains any operative content beyond cooperation and the sharing of "general information";
- whether a later protocol on high-net-worth individuals reappears on the work programme.
What is not worth reacting to is the headline. A draft article that commits states to cooperate, share general information and explore approaches, while protecting each state's right to set its own level of tax, does not justify moving assets in a hurry. It does justify an honest look at any structure whose value depends on the tax office not knowing about it. The Brief's survey of EU countries with no wealth tax shows the same pattern at European level: pressure on transparency moves faster than new taxes on wealth.
The UN text is a signal, read in its own words. Wealth that is properly declared where its owner genuinely lives has little to fear from it. Wealth that relies on staying out of sight has one more forum working on the problem.
Work with Sebastian
If you hold significant assets across several countries and want your residence, reporting and structures to hold up as information exchange widens, that is the kind of cross-border planning Sebastian works on with internationally mobile clients. Book a consultation.
