Speaking at the 4th intergovernmental negotiating committee drafting the United Nations framework convention on international tax cooperation (UNTC), Santiago stressed the political significance of Article 12 on capacity building and technical assistance.

He said Article 12 is not merely a technical provision, but a political tool to ensure that all countries, especially in the Global South, can negotiate as equals.

“For decades, the global tax system has worked well for wealthy states and multinational corporations,” he said.

“Capital moves freely, profits are protected, while many countries face eroded tax bases, underfunded public services, and widening inequality. This is not accidental. These rules were written in spaces where many countries were never fully present.”

However, Santiago said capacity building should not be seen as charity or top-down assistance.

Instead, he called for the UN to provide the resources, expertise, and analysis necessary for developing countries to fully participate in shaping global tax policies.

“If Article 12 is serious, it must break from this model through a UN-administered, independently governed, demand-driven funding mechanism that builds long-term capacity,” he said.

“Capacity building cannot be an add-on. It must be the foundation of this convention.

“Level the playing field, and fairness becomes possible. Fail to do so, and inequality will simply be rewritten into new rules.”

The UNTC is a proposed global treaty to reform international tax rules. It aims to create a more inclusive, equitable system for taxing multinational enterprises, high-net-worth individuals, and cross-border activities, addressing gaps exploited by tax evasion and avoidance.