OECD’s Pillar 2 Subject-to-Tax Rule OnPoint

The Subject-to-Tax Rule allows developing countries that are members of the OECD’s Inclusive Framework to reclaim some source jurisdiction taxing rights ceded under tax treaties with developed nations.

The rule works by allowing these countries to impose additional source-country tax on certain intra-group payments that are subject to tax in the recipient’s country of residence at a rate below 9%. Find out what you need to know.

This OnPoint discusses:

The scope of the STTR and the various limitations
The method of calculating the additional tax that may be imposed under the STTR
The administrative aspects of the STTR
The ways in which developing countries may implement the STTR into their tax treaties
The likely practical impact of the STTR and steps that taxpayers should consider before it becomes effective

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OnPoint: OECD’s Pillar 2 Subject-to-Tax Rule (STTR)