OECD: Jurisdictions sign multilateral convention implementing Pillar Two subject to tax rule
Nine jurisdictions signed the multilateral convention to implement the STTR in bilateral income tax treaties.
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September 19, 2024
Nine jurisdictions today signed the multilateral convention to facilitate implementation of the subject to tax rule (STTR).
As explained in the OECD release, the STTR multilateral convention implements the STTR—a key component (particularly for developing countries) of the Pillar Two global minimum tax rules—in bilateral income tax treaties.
- The STTR is designed to prevent circumstances where income is either taxed at very low rates or not taxed at all due to differences in tax regimes between countries by allowing jurisdictions to “tax back” when defined categories of income are subject to nominal tax rates below the STTR minimum rate of 9%, and domestic taxing rights over that income have been ceded under an income tax treaty.
- Members of the Inclusive Framework (IF) that apply nominal corporate income tax rates below 9% to income covered by the STTR have committed to incorporate the STTR into bilateral tax agreements with members of the IF that are developing countries when requested to do so.