Roadmap: Subject-to-Tax Rule (STTR) Country Status
The Subject-to-Tax Rule (STTR) 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. STTR is a key component of Pillar Two, and unlike the GloBE Rules focuses on source jurisdictions.
The Subject-to-Tax Rule (STTR) Country Status Roadmap provides an overview of the status of STTR implementation for each jurisdiction. It tracks countries that have signed the STTR MLI Pillar Two Treaty and provides links to source documents.
You’ll get the following information for each jurisdiction:
- Have they agreed to the October Statement
- Are they a “developing country” based on STTR definition
- Whether they have or intend to sign on to the STTR MLI
- Are they engaging in bilateral negotiations to implement the STTR
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