05
Oct
After releasing a model treaty provision in July, the OECD has published a multilateral convention to facilitate the implementation of the Pillar Two Subject to Tax Rule (Convention) on 3 October 2023.
Similar to the Multilateral Instrument (MLI) that enabled faster implementation of several BEPS measures, the Convention aims at accelerating the implementation of the Subject to Tax Rule (STTR), which is part of the OECD's Pillar Two measures. Similar to the MLI, the STTR only impacts an existing bilateral...