Who makes the rules: the OECD, the EU, the IMF, and the UN fight over global tax

Nobody votes for the people who write international tax law. The rules that decide how a multinational's profit is split between countries, and therefore how much tax escapes, are set in committees: the OECD in Paris, a Council working group in Brussels, the IMF in Washington, and, newly and contentiously, the United Nations in New York. Knowing who sits in which room, and who actually has a vote rather than just a seat, explains more about why the system favours scale than any single loophole does. This page is the organisation chart of global tax, and the quiet power struggle now reshaping it.

The structures on this site are downstream of these rooms. A loophole exists because a rule permits it, and the rule was written somewhere. Here is where, by whom, and with how much say for the countries on the losing end.

The OECD: the body that actually writes the rules

The Organisation for Economic Co-operation and Development has been the de facto rule-setter for international tax since the 1960s, when its Model Tax Convention first defined how countries divide the right to tax cross-border income. Its power was cemented and hugely expanded by the Base Erosion and Profit Shifting project, launched in 2013 after public anger at the tax planning of several large US technology and coffee-retail multinationals.

That project produced 15 "Action Points" and created the OECD/G20 Inclusive Framework on BEPS, which now has over 145 member countries and jurisdictions. The word "Inclusive" is doing heavy lifting, and we will come back to it. The headline output is the Two-Pillar Solution, agreed in October 2021:

• Pillar One would reallocate some taxing rights on the largest, most profitable multinationals to the countries where their customers are, regardless of physical presence, aimed at the "scale without mass" problem of digital companies. Its core component, "Amount A," covering groups above EUR 20 billion in revenue and 10% profitability, is stalled; the multilateral convention to bring it into force has not done so.
• Pillar Two sets a global minimum effective corporate tax rate of 15% for groups with revenue over EUR 750 million. As of early 2025 it is in force in over 50 jurisdictions. The EU Commission estimated member states could collectively gain about EUR 60 billion a year from it. The UK enacted it as the Multinational Top-up Tax and Domestic Top-up Tax.

The OECD makes "soft law": model conventions and guidelines that are not binding until countries adopt them, but which almost everyone adopts because the alternative is chaos. That is real power without a formal vote, and it is concentrated among the OECD's 38 members, all high-income countries.

The EU: the body with binding teeth

Within Europe, the rule-making is harder-edged because the EU can pass binding directives. The EU Code of Conduct Group, set up in 1997, polices "harmful" business-tax competition between member states. Alongside it the EU keeps an external list of "non-cooperative jurisdictions for tax purposes," the blacklist, first adopted in 2017.

As revised in February 2026, the blacklist holds ten jurisdictions: American Samoa, Anguilla, Guam, Palau, Panama, Russia, the Turks and Caicos Islands, the US Virgin Islands, Vanuatu and Vietnam. A separate "greylist" covers places that have promised reforms but not yet delivered. Listing brings consequences: higher withholding taxes, denial of deductions on payments, and tougher reporting by EU member states.

The standard criticism, from Oxfam and others, is pointed and worth stating: no major financial centre has ever appeared on the blacklist, including EU member states with their own preferential regimes, because the list is decided by finance ministers who have political reasons to protect key trading partners. The teeth are real; they tend to bite small islands rather than large enablers.

The UN: the body the losing side wants to run things instead

The most important development in international tax in decades is the push to move the whole enterprise to the United Nations, where every country has an equal vote. It began with a UN General Assembly resolution on 22 November 2023, tabled by the Africa Group, which passed by 125 votes to 48 with 9 abstentions. The split was stark: the countries voting against were predominantly OECD members. The high-income club voted, in effect, to keep the rules where it already holds the power.

Why push for the UN over the OECD? The critique is structural, not rhetorical:

• The OECD has 38 members, all rich countries. Developing countries take part in the Inclusive Framework but have no formal vote and no power to set the agenda. That is the catch in the word "Inclusive": process inclusion without power-sharing.
• The BEPS rules, especially transfer pricing and the design of Pillar Two, were built primarily to protect the interests of capital-exporting rich countries, not the capital-importing developing countries where much of the actual activity happens.
• Pillar Two's EUR 750 million threshold catches only the very largest groups, leaving untouched the medium-sized multinationals that operate heavily in developing-country markets.

The intergovernmental think tank for developing countries, the South Centre, characterises the Two-Pillar solution as a tool of developed countries designed to protect their own multinationals' profits in developing-country markets. Whether or not one accepts that framing, the procedural point is hard to argue with: the people most affected had the least say.

The status of the UN Framework Convention on International Tax Cooperation:

• Terms of Reference adopted by the Ad Hoc Committee on 16 August 2024, by 110 votes to 8 with 44 abstentions; formally adopted by the General Assembly in late 2024.
• Substantive negotiations began: February 2025, alternating between New York and Nairobi.
• Two early protocols are being negotiated: Protocol 1 on the taxation of cross-border services (a priority for developing countries, which often lack treaty rights to tax service and royalty fees), and Protocol 2 on the prevention and resolution of tax disputes.
• The draft convention text is due to the General Assembly in the second half of 2027.

If adopted and ratified, it would work like the UN climate convention: a framework body overseeing the ongoing negotiation of specific protocols, on the principle of one country, one vote. That principle is the entire point, and the entire fight. It replaces the de facto veto large economies hold in consensus-based OECD rule-making with formal equality. That is what makes it potentially transformative, and exactly why the OECD nations voted against it.

The IMF: the lender that shapes tax from the side

The International Monetary Fund does not write tax rules, but it shapes them, especially in developing countries, through technical assistance and the conditions attached to its lending. It is part of the Platform for Collaboration on Tax, a joint effort with the OECD, UN and World Bank to help poorer countries raise revenue. The criticism here is one of consistency: IMF programmes have tended to push countries towards goods-and-services taxes, the VAT and GST family, while reducing reliance on trade taxes, a shift that can raise more revenue but lean more heavily on regressive consumption taxes. The IMF's own research accepts that low-income countries could raise their tax-to-GDP ratios by an average of 6.7 percentage points if they reached their full compliance potential under current institutions. Its institutional interest in stable debt servicing and open capital markets makes it cautious about the more redistributive ambitions of the UN process.

The power map, in one table

The central dynamic in one line: the OECD sets the rules and the UN wants to reset the table. The OECD offers developing countries a process they can attend; the UN offers them a vote they can use. The outcome of the General Assembly's decision on the UN convention text, due in 2027, will be among the most consequential moments in the architecture of global tax, and it turns entirely on a question of who gets to count as a rule-maker rather than a rule-taker.