Foundation for Global Taxpayer Justice

A NGO bringing tax justice to the nations

Proposed Treaty for Global Tax Justice

A comprehensive framework for establishing just taxation policies that respect human dignity while promoting international cooperation and economic stability.

PREAMBLE

The States Parties to this Treaty,

RECOGNIZING that taxation of wages below subsistence levels treats human beings as having no inherent capital value in their personhood, reducing free citizens to a status resembling modern serfdom,

AFFIRMING that wages represent the value of human labor and personhood, not profit from capital, and that just taxation must distinguish between these fundamentally different sources of value,

RECOGNIZING the inherent dignity and equal worth of all individual members of the world as the foundation of freedom, justice, and peace in the world,

AFFIRMING that taxation policy profoundly affects human dignity, economic opportunity, and the ability of individuals to support themselves and their families,

CONCERNED that divergent national tax policies create barriers to international mobility, penalize generosity, and perpetuate cycles of economic hardship,

DESIRING to establish common principles for just taxation that respect the human worth of each individual while maintaining necessary government functions,

CONVINCED that international cooperation on tax policy can enhance economic stability and promote the free movement of peoples and cultures,

HAVE AGREED as follows:

ARTICLE 1: TAX POLICY COMMITMENTS

Section 1: Binding Initiatives

Each State Party undertakes to implement the following tax policy initiatives within its domestic legal framework:

1.1.1 Minimum Tax-Exempt Standard on Wages and Salary

Each State Party shall establish a tax-exempt threshold for wages and salaries at a level ten percent (10%) above the median cost of living for the country or, where regional variations exist, for each distinct economic region within the country. This threshold shall:

  1. (a) Be calculated annually based on objective cost-of-living data including housing, food, transportation, healthcare, utilities, and other essential expenses;
  2. (b) Apply uniformly to all residents regardless of employment type or income source classification;
  3. (c) Be adjusted automatically without requiring legislative action to reflect changes in median cost of living;
  4. (d) Represent a minimum standard, with States Parties retaining the right to establish higher tax-exempt thresholds.
  5. (e) Recognize that taxation of wages and salaries is fundamentally distinct from taxation of income derived from capital, with the former representing compensation for human labor and inherent personhood rather than profit from investment;

1.1.2 Limitation of Taxation to Residence

Each State Party shall limit the taxation of wages and salaries to individuals who are residents of that State Party for tax purposes. States Parties shall:

  1. (a) Not impose taxation on wages and salaries earned by their citizens or nationals who are resident in other countries;
  2. (b) Establish clear residency criteria based on physical presence, domicile, or other substantial connections to the taxing jurisdiction;
  3. (c) Respect the principle that individuals should not face taxation on earned wages by a state in which they neither live nor work;
  4. (d) Recognize that mobility of peoples across borders enriches cultural exchange and global community through laws that promot legal residency.

1.1.3 Tax Exemption for Gifts and Charitable Contributions

Each State Party shall exempt from taxation all gifts and charitable contributions made by individuals, whether to other individuals or to organizations. This exemption shall:

  1. (a) Apply to gifts of any amount between individuals without limitation;
  2. (b) Apply to charitable contributions to recognized charitable organizations;
  3. (c) Not require reporting or disclosure of gifts between individuals;
  4. (d) Encourage voluntary support systems and community-based assistance.

1.1.4 Elimination of Inheritance and Estate Taxation

Each State Party shall eliminate all forms of taxation on wealth transfers between generations, including but not limited to:

  1. (a) Inheritance taxes imposed on recipients of bequests;
  2. (b) Estate taxes imposed on the estates of deceased persons;
  3. (c) Generation-skipping transfer taxes;

States Parties recognize that enabling intergenerational wealth transfer reduces poverty cycles and provides economic security that allows greater flexibility in labor force participation.

1.1.5 Value Added Tax on Financial Transactions

Each State Party shall implement a value-added tax (VAT) on the sale of publicly traded stocks, bonds, derivatives, commodities contracts, crypto transactions, and other financial instruments. This tax shall:

  1. (a) Be set at a rate of three percent (3%) of the transaction value with States Parties retaining the right to establish higher percentage;
  2. (b) Apply equally to domestic and foreign purchasers and sellers;
  3. (c) Be collected at the point of transaction by exchanges, brokers, or other intermediaries;

Section 2: Proposed Future Initiatives

1.2.1 Proposed Initiatives

The following initiatives have been proposed for consideration but have not yet achieved the consensus required for adoption as binding commitments:

  1. (a) [Reserved for future proposals]
  2. (b) [Reserved for future proposals]
  3. (c) [Reserved for future proposals]

Section 3: Scope and Limitations

1.3.1 Limitations

This Treaty addresses the justice of tax policies and does not prescribe or limit government expenditure decisions. States Parties retain full sovereignty over budget allocations and institutional priorities. The Foundation for Global Tax Justice shall focus exclusively on just tax policy and shall not evaluate or comment on government spending decisions.

ARTICLE 2: AMENDMENT AND EXPANSION OF COMMITMENTS

Section 1: Proposing New Initiatives

2.1.1 Proposal of New Initiatives

Any State Party may propose a new tax policy initiative for inclusion in this Treaty by submitting the proposal in writing to the Foundation for Global Tax Justice, which shall serve as the depositary for such proposals.

The Foundation for Global Tax Justice may propose a new tax policy initiative for inclusion in this Treaty.

2.1.2 Circulation and Consideration

Upon receipt of a proposal, the Foundation for Global Tax Justice shall:

  1. (a) Circulate the proposal to all States Parties within thirty (30) days;
  2. (b) Provide a period of not less than twelve (12) months for States Parties to consider the proposal;
  3. (c) Facilitate discussions among States Parties regarding the proposal upon request.

2.1.3 Addition to Proposed Initiatives

A new initiative shall be added to Article 1, Section 2 when:

  1. (a) A simple majority of States Parties indicate support for considering the initiative; or
  2. (b) The proposing State Party or The Foundation for Global Tax Justice requests such inclusion after the consultation period (2.1.2b) has elapsed.

2.1.4 Elevation to Binding Commitment

An initiative listed in Article 1, Section 2 shall be elevated to Article 1, Section 1 and become a binding commitment for all States Parties when:

  1. (a) Three-fourths (3/4) of the States Parties have formally approved the initiative through their respective constitutional or legal processes; and
  2. (b) The Foundation for Global Tax Justice has received written notification of such approval from the requisite number of States Parties.

2.1.5 Implementation Timeline

Upon elevation of an initiative to binding status:

  1. (a) The Foundation for Global Tax Justice shall notify all States Parties within fifteen (15) days;
  2. (b) States Parties shall have three (3) years from the date of notification to implement the new commitment in their domestic legal frameworks;
  3. (c) States Parties may request a one-time extension of up to two (2) additional years by demonstrating to the Foundation for Global Tax Justice substantial progress toward implementation and the need for additional time.

ARTICLE 3: MONITORING, COMPLIANCE, AND ENFORCEMENT

Section 1: MONITORING

3.1.1 Role of the Foundation for Global Tax Justice

The Foundation for Global Tax Justice, an independent international non-profit organization, shall serve as the monitoring body for this Treaty and shall:

  1. (a) Assess the compliance of each State Party with the commitments set forth in Article 1, Section 1;
  2. (b) Publish an annual comprehensive report on the compliance status of all States Parties;
  3. (c) Provide technical assistance to States Parties in implementing Treaty commitments;
  4. (d) Serve as a forum for discussion of tax policy matters among States Parties.
  5. (e) Provide technical expertise and policy assistance to States Parties during economic transitions, downturns, and crises to help maintain just tax policies without reverting to emergency measures that violate Treaty commitments;
  6. (f) Work collaboratively with legislatures, government officials, and civil society organizations to develop implementation strategies tailored to each State Party's unique circumstances;

3.1.2 Compliance Assessment Methodology

The Foundation for Global Tax Justice shall develop and maintain transparent methodologies for assessing compliance, which shall include:

  1. (a) Review of domestic legislation and regulations;
  2. (b) Analysis of implementation in practice;
  3. (c) Consideration of information from governmental and non-governmental sources;
  4. (d) Opportunity for States Parties to provide explanatory information regarding their implementation.
  5. (e) Establish clear criteria for determining whether an initiative is "Fully Implemented," "Partially Implemented," or "Not Implemented," including:
    - Fully Implemented: All substantive requirements met
    - Partially Implemented: Significant progress made but key elements missing
    - Not Implemented: Little to no substantive compliance.

Section 2: COMPLIANCE

3.2.1 Annual Compliance Assessment and Tariff Matrix

The Foundation for Global Tax Justice shall publish annually a Compliance Assessment and Tariff Matrix that:

  1. (a) Assesses each State Party's implementation of each of the binding initiatives set forth in Article 1, Section 1;
  2. (b) Assigns a compliance status of "Implemented" or "Not Implemented" for each initiative based on substantive adherence to the Treaty requirements;
  3. (c) Calculates the number of non-implemented initiatives for each State Party;
  4. (d) Publishes the authorized maximum tariff rates between all States Parties as calculated pursuant to Article 3.2.2;
  5. (e) Provides detailed justification for each compliance determination;
  6. (f) Includes information on trends in compliance over time and steps taken toward implementation.

3.2.2 Tariff Structure Between States Parties

The maximum tariff rates that States Parties may impose on imports from other States Parties shall be determined as follows:

  1. (a) Base Maximum Tariff: The baseline maximum tariff between fully compliant States Parties shall be at maximum three percent (3%) ad valorem on all goods.
  2. (b) Non-Compliance Increment: For each initiative in Article 1, Section 1 that the exporting State Party has not implemented or only partially implemented, the importing State Party may increase its tariff by a maximum of five percentage points (5%) for non implementation or for partial implementation one to five percentage points (1%-5%) as recommended by the Foundation for Global Tax Justice.
  3. (c) Non-Signatory Increment: Imports from states that have not signed or ratified this Treaty shall be subject to a tariff of not less than ten percentage points (10%) and not more than seventeen percentage points (17%).
  4. (d) Calculation Method: The maximum tariff that State Party A may impose on imports from State Party B shall be calculated as:
    Maximum Tariff = Base Rate + (Penalty × N) + NS
    Where N = the number of Article 1, Section 1 initiatives that State Party B has not implemented and the penalty is based on 3.2.2(b) and 3.1.2(e).
    and NS = 10%-17% for non-signatories, 0% for signatories and is based on 3.2.2(c).

(e) Examples:

  • If State Party A has implemented all five (5) initiatives and State Party B has implemented all five (5) initiatives: State Party A's maximum tariff on imports from State Party B = 3% + (5% × 0) + 0% = 3%.
  • If State Party A has implemented all five (5) initiatives but State Party B has implemented only three (3) initiatives: State Party A's maximum tariff on imports from State Party B = 3% + (5% × 2) + 0% = 13%.
  • If State Party A has implemented three (3) initiatives and State Party B has implemented all five (5) initiatives: State Party A's maximum tariff on imports from State Party B = 3% + (5% × 0) + 0% = 3%.
  • If State Party A has implemented two (2) initiatives and State Party B has implemented one (1) initiative: State Party A's maximum tariff on imports from State Party B = 3% + (5% × 4) + 0% = 23%.
  • If State Party A is a signatory but Country C is not a signatory to this Treaty: State Party A's maximum tariff on imports from Country C = 3% + (5% × 5) + (10%-17%) = 38%-45%.

(f) Asymmetric Application: The maximum tariff rates are asymmetric and depend solely on the exporting State Party's compliance. A State Party with lower compliance may face higher tariffs from compliant States Parties while being limited to the base 3% rate plus increments based only on the other State Party's non-compliance.

(g) Mandatory Ceiling: No State Party shall impose tariffs on imports from another State Party in excess of the maximum tariff calculated under this Article, except as permitted under Article 3.2.2(c) for temporary trade defense measures.

Section 3: ENFORCEMENT

3.3.1 Implementation and Application of Tariff Structure

  1. (a) Binding Nature: The tariff structure set forth in Article 3.2.2 shall be binding on all States Parties. Each State Party shall adjust its tariff schedules to comply with these maximum rates within three (3) months of the annual publication of the Compliance Assessment and Tariff Matrix.
  2. (b) Right to Apply Lower Tariffs: Nothing in this Treaty shall prevent a State Party from applying tariffs lower than the maximum base rate of 3% on imports from any other State Party. However, a State Party must apply the full non-compliance increment calculated under Article 3.2.2(b) for each non-implemented initiative of the exporting State Party.
  3. (c) Trade Defense Measures: The maximum tariff rates established under Article 3.2.2 shall not prevent States Parties from applying:
    • Anti-dumping duties;
    • Countervailing duties;
    • Safeguard measures;
    Provided such measures are consistent with international trade law and are applied in a non-discriminatory manner.
  4. (d) Most-Favored-Nation Exception: States Parties acknowledge that the asymmetric tariff structure of this Treaty constitutes an exception to most-favored-nation obligations under other international agreements, justified by the legitimate policy objective of encouraging compliance with human dignity-centered tax policies.
  5. (e) Transition Provisions: For the first three (3) years following a State Party's accession to this Treaty, the incremental rate for non-compliance shall be reduced to three percent (3%) per non-implemented initiative to allow time for domestic reforms, provided the State Party demonstrates concrete progress toward implementation.

3.3.2 Dispute Resolution

  1. (a) If a State Party contests the compliance assessment made by the Foundation for Global Tax Justice, the State Party may request a formal review within sixty (60) days of the publication of the annual report;
  2. (b) The Foundation shall convene a review panel including representatives from three States Parties not involved in the dispute and if all possible from another geographical region;
  3. (c) The review panel shall issue findings within six (6) months;
  4. (d) The Foundation shall adjust its assessment if warranted by the findings.

ARTICLE 4: INSTITUTIONAL PROVISIONS

Section 1: Conference of the States

4.1.1 Conference of the States Parties

A Conference of the States Parties shall be convened:

  1. (a) Biennially in regular session;
  2. (b) In special session upon the request of one-third (1/3) of the States Parties.

4.1.2 Foundation Independence

The Foundation for Global Tax Justice shall maintain its independence and shall:

  1. (a) Be governed by a board of directors and if all possible representing diverse geographic regions and expertise;
  2. (b) Receive funding from Individual and corporate donations only;
  3. (c) Maintain transparency in its operations and decision-making processes;
  4. (d) Report annually to the Conference of the States Parties.

ARTICLE 5: FINAL PROVISIONS

Section 1: Ratification and Withdrawal

5.1.1 Signature and Ratification

This Treaty shall be open for signature by all States. It shall be subject to ratification, acceptance, or approval according to the constitutional processes of each signatory State.

5.1.2 Entry into Force

This Treaty shall enter into force on the first day of the month following the date of deposit of the second (2nd) instrument of ratification, acceptance, or approval.

5.1.3 Accession

This Treaty shall remain open for accession by any State. Instruments of accession shall be deposited with the Foundation for Global Tax Justice.

5.1.4 Reservations and Declarations

  1. (a) States Parties may not make reservations that would be incompatible with the object and purpose of this Treaty.
  2. (b) States Parties may, upon signature or ratification, declare a transition timeline not exceeding five (5) years for implementation of specific initiatives in Article 1, Section 1, provided they demonstrate concrete steps toward full compliance.
  3. (c) Such declarations shall be reviewed by the Foundation for Global Tax Justice and reported in the annual Compliance Assessment.

5.1.5 Withdrawal

  1. (a) Any State Party may withdraw from this Treaty by providing written notification to the Foundation for Global Tax Justice.
  2. (b) Withdrawal shall take effect one (1) year after the date of receipt of notification.
  3. (c) Withdrawal shall not affect obligations arising during the period of participation.

5.1.6 Depositary

The Foundation for Global Tax Justice shall serve as depositary of this Treaty and shall:

  1. (a) Receive and maintain custody of all instruments of ratification, acceptance, approval, and accession;
  2. (b) Notify all States Parties of signatures, deposits of instruments, and other communications relating to the Treaty;
  3. (c) Register the Treaty with the Secretariat of the United Nations.

5.1.7 Authentic Texts

This Treaty is established in English, French, Spanish, Arabic, Chinese, and Russian, all texts being equally authentic.

IN WITNESS WHEREOF, the undersigned, being duly authorized by their respective Governments, have signed this Treaty.

DONE at [City], this [Day] day of [Month], [Year].

ANNEXES

ANNEX A: DEFINITIONS

For the purposes of this Treaty:

  • "Cost of Living" means the monetary cost of maintaining a standard of living that includes adequate housing, nutrition, healthcare, transportation, utilities, and other necessities as determined by objective economic data.
  • "Financial Transaction" means the purchase or sale of a financial instrument through any exchange, market, or private transaction.
  • "Median" means the middle value in a range of costs when arranged in order, representing the point at which half of the population experiences higher costs and half experiences lower costs.
  • "Resident" means an individual who meets the domestic law criteria for tax residence in a State Party, typically based on domicile, physical presence, or similar substantial connection.
  • "State Party" means a Nation State that has ratified, accepted, approved, or acceded to this Treaty and for which the Treaty is in force.
  • "Wages and Salaries" means compensation for personal services, whether paid in money or in kind, including but not limited to base pay, bonuses, commissions, and other forms of employment compensation.

ANNEX B: IMPLEMENTATION GUIDELINES

[This section would contain detailed technical guidance for States Parties on implementing the Treaty commitments, to be developed by the Foundation for Global Tax Justice in consultation with States Parties.]