Eight years ago, Michael Lennard sat at the 2015 Addis Ababa Financing for Development conference and felt a growing sense of unease.
Nearly 5,000 ministers, diplomats, and tax officials had descended on Ethiopia’s largest city to commence tense discussions, including talks on whether the U.N. should create an intergovernmental tax body. Some delegates were furious even before the conference kicked off.
In the weeks leading up to Addis Ababa, it became increasingly clear that the tax body would not materialize — not without key countries like the United States and United Kingdom buying in. Yet those countries maintained that policymaking should be centered within the OECD, as it always had been.
A day before the conference began, over 600 civil society organizations fired off a sharply worded open letter accusing wealthier countries of flattening their ambitious agenda.
“It is hard to look upon the next decade and a half with great optimism based upon the Addis Agenda,” the letter said. “Not having every country represented in writing [global tax] rules to make sure they work for everyone is not only undemocratic but also unfair.”
Addis Ababa ended without that intergovernmental tax body. Instead, there was an open-ended pledge to increase international tax cooperation, but little direction on how to get there. Perhaps the largest concession to developing countries was that the U.N. Tax Committee would meet more frequently moving forward.
At the time, the 25-member group of tax experts met annually to update the U.N. model tax convention and address other international tax cooperation issues important to developing countries. After Addis Ababa, the committee started to meet twice a year in New York and Geneva.
Lennard, who is the chief of international tax cooperation in the U.N. Financing for Sustainable Development Office and secretary of the U.N. Tax Committee, returned to U.N. headquarters in New York demoralized by what he had seen.
“This is a personal view, as are all my comments, but the great pressure applied to developing countries to withdraw the call for upgrading to the U.N. Tax Committee to an intergovernmental body, and the strong argument by many developed countries against such an intergovernmental forum, soon followed by the OECD creating such a body (supported by those same developed countries), seemed rather hard to square and was perhaps an outcome that has led to some of the problems we have now,” Lennard told Tax Notes in an interview in New York.
“Had there been more actual listening to developing countries and more consideration of how to fully and genuinely create an international tax partnership, we would be closer to that now and less divided.”
One of those problems has been lingering discontent with the Addis Ababa compromise. The reality is that the calls for a U.N. tax body never went away. Some years the calls rang louder than others, but they have always hovered in the background.
Recently, African U.N. members decided to reawaken the campaign. And in November, the U.N. General Assembly approved a resolution to establish a framework convention on international tax.
The development surprised some, but not Lennard. A year before the Addis Ababa conference, he predicted that the creation of a U.N. tax body was a matter of when, not if.
“My personal view is that such an upgrade eventually will happen, and one of the biggest arguments for it is that the OECD, which functions very effectively for its members in the tax world, is an intergovernmental body,” Lennard said in a 2014 fireside chat with Jeffrey Owens, Director of the WU Global Tax Policy Centre.
Nearly a decade later, Lennard’s prediction of an expanded U.N. role in international tax has come true. In one sense, the U.N. General Assembly vote was a matter of unfinished business. In a larger sense, it fits into broader geopolitical shifts that have been gaining more attention, which tax technicians would be loath to ignore.
Recently, the Financial Times posited that we are now in an “a la carte” world in which regional powers — think Indonesia, India, Nigeria, Saudi Arabia, Mexico, and others — are using their power to navigate between the United States and China and assert their own dominance.
The New York Times recently charted Africa’s swift population boom — predicting that between now and 2050, the continent’s population will nearly double to 2.5 billion people. In other words, less than 30 years from now, a quarter of the world’s population will be African.
This is still far behind Asia, which ranks No. 1 with nearly 4.8 billion people. But it is an explosively rapid change that leaves many open questions about the future of international governance. Some of this dynamic is increasingly reflected in the international tax world, like the African drive for a U.N. tax convention.
It’s a shift that has also appeared in the U.N. Tax Committee’s own membership. “Adding an extra African to the tax committee some years ago was also a small but important step,” Lennard said. “Africa is currently such a dynamo for tax expertise and for tax justice.”
Lennard’s Road to the U.N.
Lennard says that his appointment to the U.N. was controversial for some developing countries. They saw Lennard, an Australian national, and wondered whether he could genuinely be a strong advocate for their interests. Some may have looked at Lennard’s prior experience at the OECD and questioned whether he could fully devote himself to the U.N.’s mandate.
Those assumptions came despite Lennard’s long career in international civil service and the fact that Australia, especially at that time, adopted a source-country orientation in international tax, which more aligned with the approach of developing countries.
That bit of history may come as a surprise to some because Lennard, in his nearly two-decade career at the U.N., has been one of the clearest advocates for the interests of developing countries, both on the job and in his personal capacity, Stig Sollund, a former U.N. Tax Committee member told Tax Notes.
“I do not think that, at least in the present membership, there is anyone who has even an iota of doubt about Michael’s sense of fairness and his commitment to the cause of developing countries,” said committee member Rasmi Ranjan Das.
And when you peel away the initial assumptions that followed Lennard, a different narrative emerges. At heart, Lennard is an international law and economic law expert, a practitioner whose scholarly interest in both disciplines led him to develop an encyclopedic expertise in trade and tax law.
In Australia, Lennard started his career in competition and consumer law, before joining the Australian Taxation Office (Appeals), where he practiced tax law. From the ATO, Lennard joined Australia’s Attorney-General’s Department, where he handled trade and investment law matters, including arbitration law. That experience unlocked a lifelong interest in both international law and trade law.
After the Attorney-General’s Department, Lennard did a postgraduate course in international trade law in Italy and earned a Master of International Law at the Australian National University.
Lennard also earned a master’s degree at Cambridge, where he focused on treaty interpretation and the relation of trade and environmental issues in the World Trade Organization. After Cambridge, Lennard joined the Australian Government Office of International Law, where he advised ministers, cabinet officials, and ministries on international law.
“I worked on issues as diverse as genocide, whaling, albatrosses, hazardous waste, and Antarctica, but I especially loved working on matters such as the WTO accession and cases, investment agreements, and an amicus brief to the U.S. Supreme Court on stream of commerce,” Lennard said.
“I also worked on the OECD Multilateral Agreement on Investment — those of a certain age will remember — and tax treaties,” he added.
“No one else in the office was interested in many of these matters, so I worked on very fascinating and high-level issues. And tax interested me as it is so central to a functional society, to giving people opportunities,” Lennard said. “It also addresses how countries relate to each other, how it affects individuals and companies. And there were interesting puzzles to solve.”
At the time, Lennard positioned himself for a career in international trade law. He wrote a well-cited article on WTO treaty interpretation with the support of John Jackson, the “father of the WTO,” that has been mentioned in WTO proceedings. With all this experience, Lennard thought his next step would be the WTO. But despite the prestigious resume and Jackson’s imprimatur, a few job interviews with the WTO appellate body in Geneva failed to pan out, all because of politics.
“It was soon clear that my country was not supporting me — I was from the wrong ministry,” Lennard said.
But the ATO hadn’t forgotten Lennard, and it recruited him to work on tax treaties. After two years in Australia, Lennard joined the OECD in 2003 to work on tax treaties. In 2006 he joined the U.N.
Lennard assumed the role at a time when people were making stronger links between taxation and sustainable development. Developing countries wanted organic ways to strengthen their economies. They were tired of aid. “Aid can be helpful, but it is often tied or uncertain, and it is not a long-term solution,” Lennard said.
These demands became abundantly clear in the early 2000s, when the U.N. hosted its first International Conference on Financing for Development in Monterrey, Mexico. There, U.N. countries pledged to strengthen international tax cooperation and pay special attention to the needs of developing countries.
A few years after Monterrey, the U.N. decided to change the way it handled tax matters. At the time, the U.N. hosted an ad hoc group of experts on international tax cooperation that largely handled treaty work. In 2004 it decided to rename the group and expand its mandate to make capacity building recommendations, among other things. Lennard’s role was created to support this expanded mandate.
In this growing world of tax and sustainable development, the U.N. wanted an expert with multidisciplinary experience who could navigate the interconnections between tax and other policy areas. The U.N. saw this in Lennard, and he became the committee’s sole tax-qualified secretariat member.
In this role, Lennard became a behind-the-scenes diplomat who helped steer the committee’s work by drafting provisional work agendas and documents, responding to member states’ needs for assistance, proposing workstreams and guidance products, and suggesting the right mix of experts for various subcommittees.
But when Lennard arrived at the U.N., he didn’t assume that his prior work would translate to immediate acceptance. “I had to build the confidence of those from both developing and developed countries,” he said.
“I knew I had to have tax justice at the center and the rest would follow,” he said. “Both my upbringing from my parents and my schooling in Tasmania were grounded in humility, social justice, and using your talents for the benefit of people other than yourself,” he said. “My parents were children of the Depression, and that shaped them and their values.”
Meanwhile, developed countries watched — with some curiosity and a bit of trepidation — what the souped-up U.N. Tax Committee would do and whether it would upset established OECD norms.
Lennard’s guiding philosophy was simple: “We are the secretariat to all U.N. countries. If they want our technical advice, we give it to a high standard, and we don’t tell them what their decision should be. We don’t tell them what they want to achieve. I’m happy to be assisting from the back rather than upfront. It is leadership from behind, and co-leadership,” he said.
The Rise of the Market Perspective
Profit shifting out of developing countries is hard to estimate, but there was a general sense when Lennard joined the U.N. that developing countries were navigating an increasingly untenable situation. At the time, developing countries didn’t have many tools available to them, but they did have a potential one: tax treaties. However, employing treaties to stop profit shifting was easier said than done.
The U.N. model convention — which was designed for developing countries — had only been revised once since it was first published in 1980. When Lennard arrived, updating the model was a top priority. But the official version on the U.N. documents system was corrupted, and the U.N. lacked an effective shared drive, Lennard said. Compounding the problem was that there were almost no records because former U.N. staff had a habit of clearing their computers when they left the organization.
So Lennard took matters into his own hands and eventually found a clean PDF version of the convention. For weeks, he painstakingly converted the document to Microsoft Word. Those of a certain age will know that this was a much harder task in 2006 than it is now.
But this laborious conversion provided a foundation for the U.N. Tax Committee to make some momentous changes to the U.N. model convention, first in 2011 and then in 2017 and 2021. All those changes expanded source taxing rights for developing countries.
When Lennard joined the U.N., the committee was dealing with a lingering 40-year-old issue: whether the U.N. model should allow source taxation on fees for technical services.
The U.N. had discussed the issue in the 1970s but failed to include it in the 1980 convention. In the intervening years, several individual countries took it upon themselves to include the provision within their bilateral tax treaties.
In 2013 the U.N. Tax Committee decided to work on the issue, and four years later it added new article 12A to the model convention, memorializing this growing treaty practice.
Article 12A provided a path for the committee to address another issue: the taxation of automated digital services (ADS). In 2021 the committee created article 12B, which establishes source taxation of automated digital services on a gross or net basis. Companies providing cross-border, automated digital services decide which taxing approach they prefer.
Both articles are exclusive to the U.N. model. “I think we were ahead of the pack in this respect, and history will recognize them as necessary, reasonable, and appropriate updates in the recognition of the market taxing right,” Lennard said. “The traditional permanent establishment concept based on physical presence is out of time. But it has beneficiaries, so updating it has been harder than it should be.”
“In these cases, the push came from members of the committee,” Lennard said. “I want to pay tribute to the people of courage and fortitude who make these things happen. You know, in retrospect, you can look and say, ‘Well, this change was logical.’ But it’s people of vision that you draw upon, because often they’ll be criticized, and others will ask: ‘Why are you doing this?’ It has been an honor to work with such people,” he added.
It’s too early to fully judge either article’s uptake because both are relatively new. Also, tax treaty negotiations, particularly those in developing countries, are secret and often last several years.
But Lennard noted that article 12A seems well embedded in developing country models and many newer treaties. He added that he is also comfortable with feedback he has received from developing countries that have asked the U.N. about article 12B and have said the provision is a priority in their negotiations.
“Now, that doesn’t mean you’re going to succeed on that point of negotiation,” Lennard said. “But again, I think it’s influencing the debate, including the issue of complexity versus simplicity.”
Simplicity heavily influenced the committee’s design choices. For example, some have questioned why article 12B focuses on the location of payments rather than the location of the user, or on both.
“From what I saw in operation of the committee, they felt, well, you know, that might be the case, but it adds complexity. And they thought the main problem is when payments are made, and they’re not being taxed. So I think that was a pragmatic decision,” Lennard said.
Others have also questioned why article 12B contains a net option on a company’s “qualified profits” from ADS, which are 30 percent of a company’s net income from those services. Lennard defended the net option as a big move that accommodated the concerns of business while using a simplified profit approach.
“People say, well, why is it 30 percent? It’s sort of the Massachusetts apportionment formula, which is 1/3 sales, 1/3 payroll, and 1/3 assets,” Lennard said. “I’m not sure why they didn’t put 33 percent to reflect sales, but again, I think it’s just simplicity.”
In October, the U.N. Tax Committee decided to include computer software payments in the definition of royalties, subjecting them to withholding. The committee discussed the issue for over a decade, and the length of the negotiations underscored both the importance and the depth of disagreements on the issue.
But the committee was able to make progress precisely because the U.N. model convention makes space to highlight all views on a matter, Lennard said.
“I think it’s really important that the model allows minority positions to be reflected,” Lennard said. “It’s not all or nothing. On an issue like software, you can recognize differences. The approach I’ve always liked in dealing with some of these intractable issues is trying to get people or countries as close as possible. If they are trying to achieve the same thing, try to do so in the same language and with a common understanding — minimize unintended differences and seek transparency as to the remaining ones.”
“My personal view is that’s quite important, as a lot of things right now are all or nothing,” Lennard added. “Sometimes on some difficult issues you have to show some of the differences so that business, for example, is aware of some of the interpretations and can factor them in.”
Also in October, the committee agreed to a subject-to-tax rule (STTR) which is much broader than the OECD STTR; it will not be limited to base erosion and profit-shifting concerns between related parties.
Now, a rare sign of public tension has broken out between the two organizations after an OECD document suggested that the U.N. reached its STTR decision via a majority vote. But the underlying issue is less about the STTR and more about whether the two groups make decisions via consensus or majority. Essentially, how inclusive and representative are their votes?
Lennard emphasized to Tax Notes that the committee’s decisions are overwhelmingly based on consensus, including the STTR decision. “It is not true that one organization is a consensus organization and the other is a majority vote one, as you too often hear,” he said.
“Both organizations seek consensus but they also have rules for when they can’t achieve consensus, to avoid giving any participant a veto. Sometimes in the OECD Council and subsidiary bodies it’s qualified majority ruling, which can give a special position to the largest contributors. That is different from the U.N. General Assembly where it’s one country, one vote. Seeking consensus is part of the broader systemic integrity of the process, but the consensus process needs backup, and that backup can be tailored to particular types of decisions,” Lennard said.
Real or perceived skirmishes notwithstanding, the past decade has been a particularly prolific one for the U.N. Tax Committee, and Das and Sollund praised Lennard for his stewardship of the secretariat.
“Where Michael comes in, and very effectively in that, is in informing the committee of historical background of any particular agenda item and in helping the committee to ensure that there is no overlap among various agenda items,” Das said.
“From the very beginning, and in all respects, Michael clearly showed that he had the best interests of developing countries in mind,” added Sollund. “In his reporting and drafting of mandates for subcommittees, he always made sure that this cornerstone was appropriately referenced in the work. It should be stressed that Michael always showed good understanding of the objective role of the secretariat, not taking part in substantive discussion among committee members but sometimes intervening with clarifications and procedural guidance to assist discussions as secretariat.”
‘Orphans of the Storm’
Over the past two decades, the U.N. tax committee has achieved some of its most effective and ambitious work in its entire history. And it is important to note that the committee did so on an extremely bare budget, managed by Lennard.
In 2005 the committee decided to change its approach and created ad hoc subcommittees to tackle specific projects. While the structure enabled the group to be more productive, Lennard was given few resources to support that goal, especially before the Addis Ababa conference.
“We were truly orphans of the storm,” Lennard said, adding that some subcommittee meetings were held without secretariat support. “We had no money for the members to meet, and I was not given any budget for travel other than the yearly committee session, so I would try to join those meetings when I was invited to attend conferences. Often those from developing countries could not attend either.”
In the years since, the U.N. has invigorated a trust fund for the tax committee, which has received contributions from Norway, India, the European Commission, and Sweden. Those funds are mainly used to help experts from developing countries attend subcommittee meetings on capacity building and on the translation of guidance documents into Spanish and French.
“We are a very lean operation, but it is a long way from when we were denied any office budgetary funds on the basis that we had a trust fund — even though there were no contributions,” Lennard said.
In this lean environment, Lennard said he encouraged a hard-nosed but ambitious approach by maintaining that committee members treat their four-year terms as a workplan, with an understanding that updates to the U.N. convention should be done within that time to prevent the next committee from reopening old issues.
“My approach has been to seek agreement where we can, and if that is not possible, narrow the range of differences and be transparent about them,” he said.
Reflecting on Lennard’s work, Annet Oguttu, professor of tax law at the University of Pretoria, told Tax Notes that his ability to broker agreements and compromises stems from his open manner.
“He says it as it is, but in a very gentle, diplomatic, and inclusive manner. He knows his stuff, but he has a way about him that does not antagonize people. When you have a view about something, there is a way you can say it to ensure the inclusivity of people. He has a way of being that bridging gap and having the right words to say,” Oguttu said.
Owens echoed this, telling Tax Notes that “When [Lennard is] sitting up at the podium and all hell is breaking loose between countries disagreeing, he has this beautiful, disarming smile and then comes forward with a solution that people ultimately endorse. So it’s a big advantage to have a disarming smile if you’re an international civil servant, whether at the U.N. or OECD,” he laughed.
A Seismic Shift on Transfer Pricing
A few years into the job, Lennard spotted a gap in the tax committee’s work. “I identified that most of the committee members were treaty people, as they still are, just because that’s who gets nominated. And I thought: If transfer pricing is so important, how do we get more guidance to the developing world?” Lennard said.
Resources were a concern. “I had no budget at that point for doing anything aside from attending the yearly meeting in Geneva. I had no budget to travel anywhere,” said Lennard, who eventually managed to get some funding for an expert group meeting at the International Bureau of Fiscal Documentation. Committee buy-in was also a concern. “We had to convince the people that even if they were treaty experts, that this was a sober work that they would be able to follow,” Lennard said.
“What you do is that you get people they have confidence in. Supportive and effective subcommittee chairs have been essential to our progress. Stig, who coordinated the subcommittee on transfer pricing, had the confidence of the developing and developed world,” Lennard said. And they needed that confidence because the project, at times, fell under fire from developing and developed countries alike.
From the outset, Sollund and Lennard decided that the U.N. manual would be consistent with article 9 of the U.N. model convention, its commentary, and the OECD transfer pricing guidelines. But this was unpopular with some observers and committee and subcommittee members who wanted the manual to stray from the established interpretations of the arm’s-length principle, Sollund said.
Lennard helped memorialize these intense debates in draft reports that Sollund said were helpful in keeping the mandate and fundamentals on track.
“At the start, there was extensive resistance and skepticism from business and some OECD countries, as well as within the OECD, although the OECD secretariat also rendered helpful assistance,” Sollund added. “The fear was that the U.N. might come up with a set of new guidelines that deviated from or competed with the OECD transfer pricing guidelines. Michael and I worked closely together, and we sensed that a lot of people did not want the project to succeed and hoped that we would not be able to produce the manual within the four-year term.”
At times, Sollund said, he and Lennard suspected that some participants wanted to prolong discussions rather than move forward. This included demands from business observers to have public consultations on the texts before finalization, even though the committee’s work and resource structure did not allow for full consultations, according to Sollund.
“After the first edition of the manual had been printed and published, I sensed that the resistance against the project calmed down,” Sollund said. “Critics may have seen that their fears of having something coming out of the U.N. to challenge the content of the OECD transfer pricing guidelines had been settled. The work on the second and third edition of the manual has been far less contentious, although there were many tough discussions on certain issues when developing the second edition.”
Nose-to-Tail Multilateralism
These days, several current and former heads of state are talking about international tax. In mid-November Thabo Mbeki, former president of South Africa, took to the pages of the Financial Times to support a U.N. framework convention on tax.
French President Emmanuel Macron has said he wants a concerted international tax effort to address climate action. Public awareness of international tax issues is ever growing, but Lennard largely believes that tax people have not been very good about explaining the subject to nontax people.
“It’s important to have the marriage of the tax expert and diplomatic expert. That’s challenging: They often come from different worlds. We have this issue in our tax, trade, and investment subcommittee: How do you get tax people to talk to investment people? You have to get them both to understand the perspectives of the other side,” Lennard said.
That diplomacy includes what Lennard refers to as “nose-to-tail” multilateralism and inclusiveness.
“It’s the power of deciding what is to be addressed, and of first drafting. It’s the power of giving options and opportunities to bring things into the text. What is the power of the secretariat, and who in the secretariat is making the decisions? What is their background, their life experience? How do you deal with dispute settlement, interpretation, peer review, and enforcement? The goal is that the whole experience of the treaty will be a fair one for countries that are less equipped,” he added.
“Don’t confuse capacity development on inherited norms with capacity development on bespoke fair and modernized norms,” Lennard said. “Capacity development can only be fully effective and forward-looking when founded on the latter.”
“Now, I’m a multilateralist U.N. person, a public international lawyer, but multilateralism is not really well geared towards the flexibility of keeping up with future changes. So that’s one of the great challenges: How do you end up with a regime that might work those challenges out but will work equally well in 10 or 20 years? And, you know, that depends on the provisions for amending the agreement. It depends on the willingness of states to amend it. That’s something we have to think about. It’s not being against multilateralism, but it is saying, ‘How do you achieve sufficient flexibility and certainty at the same time?’ Maybe you can learn from other disciplines, other approaches.”
So where does that leave the tax world? Lennard believes that a multilateral approach can effectively feed into a regional approach and vice versa. “Even within the regionals, you have to be careful, but differences can be accommodated,” Lennard said. “In the WTO, they have multilateral agreements where everyone agrees, but they also have plurilateral agreements where only a certain number of countries are involved.”
And that diplomacy includes partnership with the OECD and other institutions. Lennard noted that while the U.N. and OECD model conventions are often pitted against each other, the organizations have an annual course in Vienna, where participants are taught both models and then argue issues based on both perspectives.
“It’s not to convince them, but to get them to think about the other guy’s position, which is key for a real diplomat,” said Lennard.
“We’ve got great respect for the OECD. But it’s not really us [the secretariat] who first raised the issue of inclusiveness,” he said about the General Assembly vote. “We responded to member state statements and requests, and it’s ultimately an issue for member states to determine.”
And any ongoing partnership with the OECD would essentially continue the duo’s historic relationship according to Owens, who used to head the OECD’s Fiscal Affairs Division and currently is a senior adviser to the U.N. tax committee.
“The OECD secretariat has always actively participated in the work of the U.N. tax committee as have OECD member countries as well, and the hope is that there will be a continuance of constructive dialogue between the groups,” he said.
As the U.N. works on the framework convention, Oguttu thinks Lennard can play a big role, especially when it comes to discussions with the OECD.
“Now that the U.N. resolution has been taken, you can see the excitement on the side of the developing countries. But if we don’t go carefully in what we say, we may lose the ball,” Oguttu said. “There is a need for balance and to draw the developed countries on board. Just the way Michael handles himself — he is very inclusive and focuses on what can bring people together.”
“He carries the clout, the personality, the empathy, and the drive,” Oguttu added. “He has the right words to say.”
Looking to the Future
On the issue of inclusiveness, Lennard talked about the U.N. secretary general’s recent report on international tax cooperation, and his hopes for the future. He praised the high quality of the current secretariat and said he is optimistic that it will be able to tackle the challenges that lie ahead and also take up new opportunities.
The secretary general’s report, which Lennard contributed to, called on the U.N. to assume a greater role in international tax policymaking. It drew attention for what it said and what it didn’t say. In the weeks following the report’s release, some criticized it for failing to mention the OECD’s projects and successes over the years.
“This wasn’t a catalog of anyone’s good works, nor was it meant to be,” Lennard said. “People forget that it took the view that nowhere, including in the U.N. Tax Committee, is there a test of inclusiveness by right and without preconditions.”
“It’s not as though we were saying we are currently fully inclusive and [the OECD] is not,” Lennard said.
Lennard added that the importance of inclusivity extends to civil society and that he was happy to see the secretary general’s report and the November U.N. resolution call on civil society to participate in the unfolding process.
“I’ve explained to business that the civil society reference is the broader usage in the U.N., which includes business, nongovernmental organizations, academics, and other stakeholders,” Lennard said. “Business has a role in sustainable development, and NGOs are also important, because often they represent perspectives of the wider citizenry, including intended beneficiaries of tax systems.”
“I was glad to see that the [secretary general’s] report highlighted the importance of a balanced system, fair to all stakeholders. I was very keen that the report recognized the importance of dispute avoidance and resolution, which it did,” Lennard said. “And it’s important that business make the point that they’re there to work for a system that functions in a partnership for development and is not just riddled with loopholes. As long as you’re balanced and you treat everyone with respect, then you’ll end up with a system that’s fair, even if not everyone is entirely happy with it.”
It’s a philosophy that Lennard has personally embraced, and one that has enabled him to work in often challenging circumstances.
“You only succeed in this sort of low-resource, small-secretariat environment by reaching out to people of goodwill, including people from business, including people from NGOs and academia, but particularly from governments and people on the committee,” Lennard said. “We say, ‘Yes, this will be a learning experience. But through learning more, we can actually give more guidance to developing countries.’”
For nearly 20 years, stakeholders have taken Lennard up on his offer because they recognize that there is no other path, given the high stakes at play for developing countries. Similarly, Lennard has given his all, both professionally and personally, in ways that have both enriched the tax world and proved his own mettle in the toughest times.
“Doing some of my hardest work while undertaking simultaneous radiotherapy and chemotherapy, and then major cancer surgery (successfully, and well supported by my wife), was something I am proud of — because there was no alternative,” Lennard said. “As someone who watched the first moon landing from school in distant Tasmania and who has been forever inspired by the Apollo project, I recognize the importance of high ambition and the acceptance that sometimes, on the biggest projects, failure is simply not an option.”
