EVER since he has become the 47th President of the United States, Mr. Donald Trump has turned the world topsy-turvy. In his world view, the international order whether in the sphere of the balance of power between states or running of international institutions, or in the sphere of international trade or for that matter in international taxation, nothing exists beyond the USA. The ‘America first' policy must be followed not only by the USA itself, but also by all other nations. It is as if the USA is now following its mortal rival China which used to (and may be, still does) consider itself as the central kingdom surrounded by barbarians. Every day, Mr Trump's demands some change or the other from sovereign nations and we see the spectacle of the leaders of the so-called great western powers come to Washington and kow-tow before him with promises of investments in the USA. The moniker of the ‘Middle Kingdom' may now be justly applied to the USA as it prefers to be surrounded by ransom paying vassals. Perhaps Mr Trump also expects the same obsequious behaviour from India, a country unlikely to forget how mercilessly it was looted and plundered for centuries by the colonists and much of the wealth of the modern west is built on such mercantilist behaviour of the erstwhile rulers and their enablers.

Mr. Trump is also a man in a hurry . He is pushing 80 and wants to be remembered as the greatest President of the USA. To that end, he is also obsessed with his quest for a Nobel Peace Prize. But why this obsession? It appears that in his first term, the then Japan's Prime Minister Shinzo Abe had indeed nominated him for the prize following his talks with Kim Jong Un where they discussed the country's nuclear weapons programme. 1 He is, of course, particularly piqued by the fact that Barack Obama got the prize for doing nothing. It is true that Mr. Obama himself stated:

"I would be remiss if I did not acknowledge the considerable controversy that your generous decision has generated. In part, this is because I am at the beginning, and not the end, of my labors on the world stage. Compared to some of the giants of history who've received this prize -- Schweitzer and King; Marshall and Mandela -- my accomplishments are slight"

Mr. Trump has often complained that he has solved seven major conflicts in seven months but will not get the Nobel Peace Prize. Solving international conflict may indeed be a criterion for winning the prize. Mr. Trump has often boasted in his campaign trail that he would solve the Russia- Ukraine conflict on day one in his office. Day one has come and gone; the end is nowhere in sight. Caught in the crossfire is India for refusing to allow him to take credit for ending the Indo-Pak conflict which, according to him, was going nuclear. Mr Trump has also promised to solve the Israel-Gaza conflict which, he repeats, would not have happened if he were the President -a hypothetical rhetoric that no one can verify. Mr. Trump's quest for the Nobel peace Prize led me to look up the other American politicians who have won the Prize earlier.

Indeed, four American Presidents and one Vice President have so far won the Nobel Peace Prize- Theodore Roosevelt of the Republican Party, in 1906, President Woodrow Wilson in 1920 (for his efforts at establishing the League of Nations), President Jimmy Carter in 2002, Vice President Al Gore in 2007 and President Barack Obama in 2009.

According to Alfred Nobel's will, the Nobel Peace Prize shall be awarded to those who have " done the most or the best work for fraternity between nations, for the abolition or reduction of standing armies and for the holding and promotion of peace congresses."2

Judging by that standard, Theodore Roosevelt's award was the most controversial. " The Norwegian Left argued that Roosevelt was a "military mad" imperialist who completed the American conquest of the Philippines. Swedish newspapers wrote that Alfred Nobel was turning in his grave, and that Norway awarded the Peace Prize to Roosevelt in order to win powerful friends after the dramatic dissolution of the union with Sweden the previous year."

He received the Peace Prize for having negotiated peace in the Russo-Japanese war in 1904-05 and also for having resolved a dispute with Mexico by resorting to arbitration as recommended by the peace movement.3

Mr. Woodrow Wilson won the Peace Prize for 1919 as the architect behind the League of Nations (LON). It was to ensure world peace after the slaughter of millions of people in the First World War.4 Ironically, it was Mr Theodore Roosevelt, the first Nobel Peace Prize winning President of the USA and who was a senator at that time who opposed the idea and the USA could not ultimately join the newly created LON thereby reducing its credibility. But it is widely accepted that after the second world war, the United Nations was largely built on the Wilsonian idea of cooperation rather than competition amongst nations.

Now, on the occasion of the 80th session of the General Assembly while delivering his address to all the member country dignitaries assembled there, Mr Trump seems to have dissociated himself from the central idea of the United Nations, putting America at the front and centre of the universe. Some excerpts from his speech as available from the White House are worth noting. It is titled-

At UN, President Trump Champions Sovereignty, Rejects Globalism (September 23, 2025)

"America is blessed with the strongest economy, the strongest borders, the strongest military, the strongest friendships, and the strongest spirit of any nation on the face of the earth. This is indeed the Golden Age of America."

"In a period of just seven months, I have ended seven ‘un-endable' wars… No President or Prime Minister - and for that matter, no other country - has ever done anything close to that… It's too bad that I had to do these things instead of the United Nations doing them - and sadly, in all cases, the United Nations did not even try to help ."

"What is the purpose of the United Nations ? The UN has such tremendous potential… All they seem to do is write a really strongly worded letter, and then never follow that letter up. It's empty words - and empty words don't solve war."

"Everyone says that I should get the Nobel Peace Prize … but for me, the real prize will be the sons and daughters who live to grow up with their mothers and fathers because millions of people are no longer being killed in endless and un-glorious wars. What I care about is not winning prizes, it's saving lives."

"A dramatically better future is within our reach - but to get there, we must reject the failed approaches of the past and work together to confront some of the greatest threats in history."

"My position is very simple: the world's number one sponsor of terror can never be allowed to possess the most dangerous weapon."

"Now, as if to encourage continued conflict, some of this body is seeking to unilaterally recognize a Palestinian state… Instead of giving in to Hamas's ransom demands, those who want peace should be united with one message: release the hostages now!"

"China and India are the primary funders of the ongoing war by continuing to purchase Russian oil - but inexcusably, even NATO countries have not cut off much Russian energy."

"Not only is the UN not solving the problems it should, too often, it is actually creating new problems for us to solve … The United Nations is funding an assault on Western countries and their borders … The UN is supposed to stop invasions, not create them and not finance them."

"What makes the world so beautiful is that each country is unique - but to stay this way, every sovereign nation must have the right to control their own borders ."

"I'm telling you that if you don't get away from the ‘green energy' scam, your country is going to fail. If you don't stop people that you've never seen before that you have nothing in common with, your country is going to fail."

"The entire globalist concept of asking successful, industrialized nations to inflict pain on themselves and radically disrupt their entire societies must be rejected completely and totally - and it must be immediate."

"The challenge with trade is much the same as with climate: the countries that followed the rules, all their factories have been plundered… by countries that broke the rules. That's why the United States is now applying tariffs to other countries."

"Together, let us defend free speech and free expression. Let us protect religious liberty, including for the most persecuted religion on the planet today - it's called Christianity."

(Emphasis added)5

But, Donald Trump, notwithstanding or should we say, despite Mr. Donald Trump, there is a world beyond the USA. Countries still wish to collaborate instead of competing in many fields including in the field of international taxation and a momentous event particularly from the point of view of the developing countries took place in the month of February and August, 2025 in New York at the United Nations.

In an earlier episode, I have already discussed the initiative to create the United Nations Framework Convention on International Tax Cooperation (UNFCIT). The first organisational session of the UNFCIT took place at the United Nations headquarters from 3rd to 6th February, 2025 . Eurodad reports that the US delegation stayed quiet during the morning session. However, at the start of the afternoon session, the US, delegation announced that they objected to the process, and would no longer be participating. Apparently, the US had called for other countries to also leave the convention negotiations with them, but nobody did, and in the end, they had to walk out alone.6

The United States' Mission to the United Nations, however submitted an Explanation of vote and it is necessary to take note of the same –

"The United States takes this opportunity to state firmly and clearly that the goals of a future UN Framework Convention on International Tax Cooperation are inconsistent with U. S. priorities and represent unwelcome overreach . We do not plan to participate further in this organizational session, process, or negotiating United Nations Framework Convention on International Tax Cooperation text.

We reject the very nature of these discussions. The process that has been adopted will lead to a Convention that would unacceptably hamper nations' ability to enact tax policies that serve the interests of their citizens, businesses, and workers.

Further, within these discussions, we underscore our profound objection to the process thus far. We have repeatedly voted "no" to express our concerns with the direction and the evolution of the decision-making process away from consensus and have been met only with inflexibility.

Finally, we underscore that the United States intends to reject the outcomes of this Framework Convention process and oppose them. We welcome others to join us in opposition."7

The default rule at the UN General Assembly is not consensus but majority. Therefore, the insistence of the US as also some others (EU) to adopt consensus for taking any decision would make the process wholly unworkable. Nations have watched the OECD process where the decisions are taken apparently on consensus but one does not know if such consensus is really consensus. Besides, the USA has misused the process and participated only to dilute resolutions and then refused to sign on as has happened with both the OECD Pillars one and two. The politics is now exposed. As explained by Tove Maria Ryding of Eurodad:

"The withdrawal of the US became a perfect illustration of why the UN Tax Convention process should not introduce consensus decision-making. With the current rules, the US can stay or go, but they cannot prevent other countries from moving ahead in the negotiations . And that is exactly what will happen now. Every country can decide for themselves whether or not they want to sign the Convention, but it should not be up to one single country to decide whether or not the others are allowed to work together."8

Nevertheless, the delegates did debate seriously the issue of consensus and in the end a hybrid approach was finally adopted- two-thirds majority voting for substantive issues and simple majority voting for non-substantive procedural matters when consensus fails.9

At the adoption of the terms of reference , it was already decided that the delegates would work on an early Protocol relating to the income derived from the provision of cross-border services. Taxation of services is an issue totally ignored by the OECD BEPS project. But it is vital for preventing base erosion and thereby raising resources in the developing countries. From the Indian experience we know how difficult it is to tax this stream of cross-border income and how easy it is to erode the tax base of source countries. I come across very few India cases where attempts at taxing payments as royalties, or fees for technical services or classify payments made for software etc under a neat head have succeeded. Therefore, it is very important that the workstream-1I relates to this important subject, workstream I being the Framework Convention itself.

In the meantime, the UN Committee of Experts have already finished their work on taxation of services, which we will discuss in a subsequent article and although the exact relationship between the Committee of Experts where delegates work in their personal capacity as experts appointed by the Secretary General and the delegates working as representatives of their national governments as part of the Framework Convention on International Tax Cooperation are not clear, nevertheless, it is likely that the work of the tax committee is likely to influence the future contours of the Framework Convention.

In the February session, the delegates also finalized the second topic for the early Protocols- The Prevention and Resolution of Disputes . The delegates had also considered the taxation of high net-worth individuals but finally settled on the tax dispute resolution as the second topic. This is an area where the OECD countries were pushing for compulsory arbitration in cases that could not be resolved within a certain period of time and there was pushback from developing countries and ultimately a Competent Authority centric dispute resolution was adopted as Action point 14 of the BEPS Project. But developing countries lack resources in this area. The problem is further compounded by resourceful private sector players resorting to Interstate Dispute Resolution mechanism of the Bilateral Investment Treaties (Vodafone- Cairn etc). It is expected that the Framework Convention will address such concerns that impinge on the sovereignty of nations.

The second session of the Framework Convention took place again in New York in August 2025 . Countries discussed seriously the various workstreams- 1 relating to sustainable development, fair allocation of taxing rights, and effective dispute resolution. Obviously, different countries have differing interpretations of fairness and taxing rights. As for the Protocol on Taxation of cross border services, relevance of Significant Economic Presence as a nexus was discussed. Similarly, discussion on Workstream III relating to dispute resolution and concomitant issues were further discussed. The cleavage of the stand of the developed and developing countries continued to manifest itself during the discussions.

Nevertheless, it has to be admitted that the initiative in which the Africa Group played a vital part is an attempt to assert the power of the developing countries as a group in the field of setting rules of international tax. As pointed out by the representative of Ghana speaking for the Africa Group-

"This is not just another meeting. It is the first time in history that the global community – under the auspices of the United Nation – is coming together to design a new international framework convention on tax cooperation, one that is inclusive, one that is just, and one that is driven by shared principles rather than power asymmetries."10

We may recall that the provision of revenge tax proposed by the USA in Mr. Trump's One Big Beautiful Bill was dropped when the G-7 (not G-20) agreed that the US multinationals will be kept outside the global minimum tax framework . In this connection, the Africa Group observed:

"The recent announcement by the G7 to exempt some countries from their commitments under Pillar 2 serves as a powerful reminder of the broken nature of the current tax architecture. It highlights a truth many of us have long known – that the status quo is not only inadequate, it is unfair."11

He also added: The African Group comes to this session with full determination and a deep sense of responsibility. We are not here to replicate old structures or reinforce existing imbalances. We are here to co-create something new. A system that works for all. A framework that levels the playing field. A convention rooted in equity, transparency and the sovereign right of every nation to raise revenue justly from the economic activity that occurs within its borders." 12

Meanwhile, in the BRICS joint declaration in June 2025, support was extended to the UN framework:

"We support the establishment of a United Nations Framework Convention on International Tax Cooperation (UNFCITC) as a decisive step to an inclusive, effective, equitable, and fair global tax architecture. The Convention represents a historic opportunity to improve international tax cooperation and ensure meaningful representation of all United Nations members, including emerging and developing economies, in the design of tax frameworks . Inclusive and effective international tax cooperation must be based on universal principles, general objectives, and commitments to enhance mutual understanding among parties. We also recognize the role of the early protocols, serving as legal instruments and provisions that contribute to achieving the Sustainable Development Goals. In this regard, we encourage active participation in the design of the two early protocols, aiming for a balanced and development-oriented approach. By promoting a fair allocation of taxing rights under the international tax system, our cooperation will be based on tax sovereignty, building a framework that allows all countries to adapt and implement provisions in accordance with national circumstances, needs, and priorities. We will continue our efforts to make tax systems more transparent, fair, simple, and efficient, fostering balanced economic growth. To advance commitments in line with the Terms of Reference, our efforts must promote effective mutual assistance in tax matters, improve transparency, and address tax-related illicit financial flows, as well as curb harmful tax practices and tax evasion, including by high net-worth individuals. We call on all United Nations members to join in our efforts to build fair and more inclusive tax systems fit for the 21st century."13

Mr Trump has earlier threatened to impose additional tariffs on BRICS as he considers the grouping as a threat to the US hegemony. He has already imposed highest tariffs on two of the founding members @ 50% on Brazil and India although for diverse stated reasons. Nevertheless, the UN process chugs on.

__________________________________________

1 https://news.sky.com/story/why-donald-trump-believes-he-deserves-the-nobel-peace-prize-and-ended-seven-wars-13415259

2 https://obamawhitehouse.archives.gov/blog/2014/12/10/day-history-four-presidents-and-vp-received-nobel-peace-prize#:~:text=Since%20the%20creation%20of%20the,each%20year%20on%20December%2010

3 Theodore Roosevelt – Facts. NobelPrize.org. Nobel Prize Outreach 2025. Fri. 26 Sep 2025.

4 Woodrow Wilson – Facts. NobelPrize.org. Nobel Prize Outreach 2025. Sat. 27 Sep 2025.

5 https://www.whitehouse.gov/articles/2025/09/at-un-president-trump-champions-sovereignty-rejects-globalism

6 https://www.eurodad.org/us-walks-out-tax-convention

7 https://usun.usmission.gov/statement-at-the-session-for-the-intergovernmental-negotiating-committee-on-the-un-framework-convention-on-international-tax-cooperation

8 https://www.eurodad.org/us-walks-out-tax-convention

9 https://www.iisd.org/articles/explainer/united-nations-international-tax-convention-negotiations

10 https://www.eurodad.org/breaking_the_ice_in_the_un_tax_convention_negotiations

11 ibid

12 ibid

13 http://www.brics.utoronto.ca/docs/250705-1st_BRICS_FMCBG-Tax.pdf