Advisory Services for Global Tax Consultancy

A. Purpose of this Expression of Interest The Secretary-General of the United Nations seeks experienced global tax advisors to the Office of Investment Management (“OIM”) of the United Nations Joint Staff Pension Fund (“UNJSPF” or the “Fund”). B. Brief Description of the Fund The UNJSPF was established as a Subsidiary Organ of the United Nations ("UN"), by the General Assembly of the United Nations in 1949 to provide retirement, death, disability and related benefits for the staff of the UN and other organizations admitted to membership in the Fund. It operates as a defined benefit plan. The Secretary-General has delegated his fiduciary and trustee responsibilities to the Representative of the Secretary-General (“RSG”) for the Investments of the UNJSPF. In day to day investment operations, the Representative of the Secretary-General is assisted by the staff of the OIM. The UNJSPF has approximately US $88 billion under management as of 31 December 2023, approx. 73% managed internally and other 27% managed by external managers. At the same date, the UNJSPF’s assets were invested in approximately 35 currencies with investments in 72 countries (including emerging markets), in regional institutions and international institutions, and in institutional investment trusts. C. Privileges and Immunities – Tax Exempt Status Paragraph 1 of Article 105 of the UN Charter provides that the UN shall enjoy in the territory of each of its Member States such privileges and immunities as are necessary for the fulfillment of its purposes. As a subsidiary organ and integral part of the UN, the UNJSPF benefits from such privileges and immunities. The Convention on the Privileges and Immunities of the United Nations (“Convention”) elaborates on the privileges and immunities of the UN. In particular, Section 7(a) of the Convention provides that the United Nations, its assets, income and other property shall be exempt from all direct taxes. On this basis, the income from the investments of the UNJSPF in the territory of each of the UN’s Members, including dividends, interest and capital gains, is to be treated as tax exempt. The Convention also grants the UN and its property wherever located or by whomsoever held, immunity from every form of legal process, except insofar as in any particular case it has expressly waived its immunity. D. Brief description of Services The UNJSPF seeks to retain the services of a global tax advisor to (i) ensure it benefits from relief at source wherever available, (ii) streamline its tax reclamation efforts in certain markets, (iii) establish a relief at source or reclaim process in jurisdictions where such mechanisms have not yet been formally implemented, (iv) determine a course of action for the recovery of historical taxes and take the necessary steps to recover these withholdings wherever financially feasible, and (v) provide advice pertaining to the structuring of the Funds future investments in real estate, commodities and other funds in which the UNJSPF may transact which would ensure the recognition of its tax exempt status by relevant local tax authorities.