Analysing the Impact of UN and OECD Subject to Tax Rule for G-24 and South Centre Member States
By Suranjali Tandon and Chetan Rao
The Subject to Tax Rule (STTR) is meant to address base erosion and profit shifting in cross –border transactions. The United Nations (UN) and Organisation for Economic Co-operation and Development (OECD)/Group of Twenty (G20) Inclusive Framework have developed models of the STTR that countries may choose to adopt in their treaties. This paper provides a review of these designs of two STTR models and proceeds to estimate the revenue gains for the Intergovernmental Group of Twenty-Four on International Monetary Affairs and Development (G-24) and South Centre Member States that may arise from a STTR that covers different kinds of payments. The OECD STTR is limited to related-party payments and imposes thresholds based on mark-up and materiality, reducing its applicability in practice. In contrast, the UN STTR offers broader coverage, applies to both related and unrelated parties, and does not impose restrictive thresholds, making it more administratively feasible for developing countries. Although the estimated gains from the OECD STTR appear modest due to its narrow scope, the UN STTR shows greater potential. The analysis also highlights data limitations and the need for access to microdata for accurate country-level assessments.
WTO Reform: Structuring a Positive Agenda for Developing Countries
A Working Document on Structuring Reform Around Legal Principles and Development Priorities, 15 July 2025
By Vahini Naidu, Trade for Development Programme, South Centre
This Working Document outlines a structured contribution to the WTO reform process from a legal and developmental perspective. It organises the wide range of reform issues into seven categories, based on their legal character, institutional handling, and the procedural steps required for meaningful resolution. The aim is to support a more coherent and inclusive reform process by offering a logical framework grounded in the Marrakesh Agreement and reflective of the WTO’s foundational principles. It is intended to assist Members in navigating reform discussions in a manner that is principled, transparent, and responsive to the priorities of developing countries.
WTO Reform: Framing Challenges in the Facilitator-led Process and Strategic Considerations for Developing Countries
By Vahini Naidu, Trade for Development Programme, South Centre
This Informal Note was prepared to inform developing country participation in the next round of Facilitator-led consultations on WTO reform. It provides a critical reflection on the three-track framework proposed by the Facilitator, namely Governance, Fairness and Future, and raises concerns about the framing, legal coherence, and process legitimacy of the emerging reform agenda. The note highlights the risks of implicitly reshaping negotiating priorities through informal structuring, particularly in ways that may disadvantage developing countries or dilute existing legal mandates. It offers strategic considerations and suggested responses to the three guiding questions posed by the Facilitator, underscoring the need to reaffirm treaty-embedded rights such as Special and Differential Treatment, preserve institutional integrity, and ensure that any reform remains firmly anchored in multilateral principles, Member-driven processes, and the development dimension. A separate working document proposing a structured positive agenda for developing countries will follow to complement this analysis.
Gender Intersectionality in Antimicrobial Resistance
Webinar Report
The South Centre held a webinar on Gender Intersectionality in Antimicrobial Resistance (AMR), on 14 May 2025, with the participation of experts from academia, independent research institutions and international organizations. The webinar was attended by over 70 participants from around the world, demonstrating interest in gaining greater understanding of the gender dimension in effective strategies fortackling antimicrobial resistance.
WTO Reform: Facilitator’s Report on Initial Consultations (JOB/GC/445)
Commentary, 9 July 2025
By Vahini Naidu, Trade for Development Programme, South Centre
This commentary provides a critical analysis of the Facilitator’s Report on Initial Consultations on WTO Reform, highlighting the absence of a shared reform objective, the fragmentation of issues, and the risks posed to developing country priorities, particularly with respect to the Special and Differential Treatment and self-designation, and the consensus-based decision-making. It examines the legal and institutional implications of current reform narratives and cautions against proposals that may entrench rather than correct systemic imbalances.
South Centre Inputs on the Draft Issues Notes on the UN Framework Convention on International Tax Cooperation
11 July 2025
In preparation for the First and Second Sessions of the Intergovernmental Negotiating Committee (INC) on the United Nations Framework Convention on International Tax Cooperation (UNFCITC) to be held in August 2025, the Co-Leads of each of the three Workstreams have released Draft Issues Notes for public comments. The Issues Notes are meant to provide direction on the content of the UNFCITC and its two early protocols on services and dispute prevention and resolution.
Policy in Practice: Implementing Antimicrobial Stewardship Post-COVID-19
Q&A and Commentary
By Dr Rasha Abdelsalam Elshenawy
This report summarises the key questions and expert commentary for the South Centre, as well as the South Centre Policy Brief on lessons from the COVID-19 pandemic, to strengthen antimicrobial stewardship and provide practical recommendations discussed during the South Centre webinar on “Strengthening Antimicrobial Stewardship: Policy Insights from COVID-19 and Future Pandemic Preparedness.”
Advancing Women and Girls’ Health in a Time of Converging Crises
South Centre Briefing Session (April 2025) Report
The South Centre hosted a high-level briefing session aimed at advancing the health rights of women and girls in the face of multiple global challenges. The meeting coincided with the South Centre’s 30th anniversary and the 30th anniversary of the Beijing Declaration and Platform for Action, bringing together ambassadors, health experts, and representatives of international organisations to discuss the protection and advancement of sexual and reproductive health and rights (SRHR) in the Global South.
Scope of Compulsory License and Government Use of Patented Medicines
To meet public health needs governments can use compulsory licenses and government use as a tool for procurement and import of patented medicines. These mechanisms are provided for in most laws worldwide. The WTO TRIPS Agreement, as reaffirmed by the Doha Declaration on TRIPS and Public Health, recognises the right of WTO members to grant compulsory licenses and their freedom to determine the grounds upon which such licenses may be granted.
This table provides information of instances of their use.
Advancing National Action Plans on Antimicrobial Resistance amidst Health Financing Challenges
By Afreenish Amir
The South Centre held a webinar on advancing national action plans (NAPs) on Antimicrobial Resistance (AMR) amidst health financial challenges, on 20 March 2025. The webinar brought together various national focal point leads for NAPs on AMR and international experts.
Contribución del Centro Sur al Informe del Secretario General de las Naciones Unidas sobre la aplicación de la Resolución A/RES/79/7 de la Asamblea General sobre la “Necesidad de poner fin al bloqueo económico, comercial y financiero impuesto por los Estados Unidos de América contra Cuba”
Esta contribución del Centro Sur se presenta en respuesta a la solicitud del Secretario General como un aporte al informe del Secretario General de acuerdo a la resolución A/RES/79/7, con respecto a la imposición de medidas económicas, financieras y comerciales unilaterales por parte de los Estados Unidos de América, contra Cuba, en violación de los principios básicos de la Carta de las Naciones Unidas y el Derecho Internacional.
