OECD: Albania signs multilateral convention implementing Pillar Two subject to tax rule
10th jurisdiction to sign the multilateral convention to implement the STTR in bilateral income tax treaties
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September 25, 2025
Albania has signed the multilateral convention to facilitate implementation of the subject to tax rule (STTR), becoming the 10th jurisdiction to sign the agreement.
As explained in the OECD release, the STTR is a treaty-based rule applying to a defined set of cross-border intragroup payments.
- When these payments are subject to a corporate income tax rate below 9% in the recipient’s jurisdiction of residence, it allows the jurisdiction of source to apply additional tax up to that minimum rate.
- Members of the Inclusive Framework (IF) on BEPS 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 IF members that are developing countries when requested to do so.
- The STTR multilateral convention enables implementation of the STTR in existing bilateral tax treaties without the need for bilateral amendments.