G20: Adopted OECD Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR Multilateral Instrument)
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Description
Adopted OECD Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR Multilateral Instrument)
On 3 October 2023, the OECD adopted the "Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule" (STTR Multilateral Instrument). The Convention will allow to implement the Pillar Two Subject to Tax Rule in existing bilateral tax treaties without the need for bilateral negotiations. It will also allow developing countries to tax certain intra-group payments, in instances where these payments are subject to a nominal corporate income tax rate below 9%. The convention is now open for signing.
Original sourceScope
Policy Area
Taxation
Policy Instrument
Direct taxes including Digital Service Taxes
Regulated Economic Activity
cross-cutting
Implementation Level
bi- or plurilateral agreement
Government Branch
executive
Government Body
other regulatory body
Complete timeline of this policy change
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2021-07-01
adopted
2021-07-10
adopted
2021-10-08
adopted
2021-12-20
adopted
2022-02-04
in consultation
2022-02-18
processing consultation
2022-03-14
in consultation
2022-04-11
processing consultation
2022-12-20
in consultation
2023-01-20
processing consultation
2023-07-11
adopted
2023-10-03
adopted