Comparing Two Subject to Tax Rules: The United Nations vs. the OECD/Inclusive Framework – Which Version Is Better for Developing Countries?

In this article, the authors examine the evolution and rationale of the Subject to Tax Rule (STTR), comparing provisions developed by the UN and the OECD/Inclusive Framework. They analyse existing treaty applications, implications for developing countries and alternative policy options to address base erosion and profit shifting, concluding with recommendations for future approaches.