Beneficial ownership transparency and the UN Tax Convention: Connecting information to strengthen fair and effective tax systems

Christine Wachira, Regional Associate for Africa, delivering Open Ownership's statement at the UN Framework Convention on International Tax Cooperation in November 2025

As governments meet in Nairobi to negotiate the United Nations Framework Convention on International Tax Cooperation (UNFCITC), there is an important opportunity to strengthen how governments exchange and use information about who ultimately owns and controls wealth and assets.

Clear and connected beneficial ownership (BO) information is essential to building fairer, more effective tax systems and ensuring that public revenues are protected from misuse. Open Ownership is advocating for strong and ambitious commitments to beneficial ownership transparency within the Convention, including commitments to national reforms, and a United Nations (UN) Global Asset Register. This is an opportunity to provide a clear UN mandate to develop systems, standards, and cooperation mechanisms needed to comprehensively connect ownership and asset information across borders.

Why beneficial ownership transparency matters for fair taxation

Information about beneficial ownership lies at the heart of a fair and effective tax system. With accurate beneficial ownership data, governments can more effectively mobilise domestic resources, strengthen tax collection systems and safeguard public revenue—thereby supporting sustainable development and public services

Connecting ownership data across borders helps close key loopholes that enable tax evasion and illicit financial flows. By shining a light on opaque ownership structures that enable abuse such as anonymously owned shell companies, beneficial ownership transparency helps ensure that taxation is fair, transparent and aligned with the actual flow of value, strengthening the integrity of both public finances and markets — supporting trust, accountability, and sustainable economic growth.

Advancing beneficial ownership through the UN Tax Convention

Open Ownership has joined civil society partners from across the globe in calling for beneficial ownership transparency to be explicitly included in the UN Tax Convention. The joint submission of the Global Alliance for Tax Justice (GATJ), to which Open Ownership is a signatory, recommends that the Convention:

• Creates a comprehensive global register linking assets, companies, and other legal vehicles to their beneficial owners. The Global Asset Register (GAR) should build on national beneficial ownership reforms, include both public and confidential components, and guarantee automatic exchange of information among all Parties.
• Adopts a multilateral system for automatic information exchange, based on a common standard, as part of the GAR. All Parties should have access on an equal footing, with a transition phase allowing developing countries to receive data on a non-reciprocal basis until they have capacity to reciprocate. This would replace slow, request-based systems with structured, timely exchange.
• Mandates all countries to establish verified, standardised national registers of the beneficial owners of companies and other legal vehicles, interoperable with the GAR. These should allow public access to key ownership data, while keeping sensitive information confidential but available to competent authorities.

These recommendations reflect a growing consensus that beneficial ownership transparency is vital to building fairer, more effective tax systems, and set out a strong framework for embedding beneficial ownership transparency in the Convention.

Connecting data for effective implementation

From our work with governments worldwide, Open Ownership has learned that the most effective approach is to connect and improve existing systems rather than create entirely new ones. Therefore, effective solutions developed under the Convention should:

• Build on what exists. National BO registers for companies and trusts, as well as existing shareholder and nominee registers and asset databases, already contain valuable information. Connecting and harmonising these sources will be more effective and efficient than collecting new data.
• Prioritise data quality and interoperability. Structured, standardised, and verifiable information enables reliable analysis and exchange.
• Link BO data for legal vehicles with asset registers. Connecting legal vehicle and asset records (such as land or property) through shared identifiers helps tax authorities see complete ownership networks.
• Improve understanding of direct ownership relationships. Clear, comparable data on direct links between e.g. a company and a trust, reduces duplication, improves accuracy and reduces reporting burdens.
• Enable structured, timely access. Moving from ad-hoc information exchange toward authorised, real-time access strengthens enforcement and cooperation.
• Ensure clear governance and purpose. Clarity over why and how information is used supports trust, compliance, and defines legitimate access.

Applying these approaches will help countries make ownership transparency an integral part of strong, fair, and resilient tax systems.

Looking ahead

The UN Tax Convention presents an important opportunity to embed beneficial ownership transparency into the global tax cooperation architecture. By supporting the proposals set out in the GATJ submission, governments can help ensure that the Convention establishes the standards, systems, and cooperation mechanisms needed to connect ownership and asset information across borders.

Strengthening beneficial ownership transparency will empower countries to raise more revenue fairly, prevent corruption and money laundering, and foster confidence in financial and governance systems worldwide.

Open Ownership will continue to work with governments, international organisations, and others throughout civil society to shape the commitments made within the Convention and subsequent protocols, and bring our experience to bear to ensure that commitments made can be translated into practice.