Earth to OECD: You Must Be Joking – The Subject to Tax Rule of Pillar Two

Journal
Arnold, B.J.
International; OECD
Bulletin for International Taxation 2024 (Volume 78), No. 2
FormatPDF
EUR
45
| USD
50 (VAT excl.)

In this article, the author examines the implications of the Subject to Tax Rule (STTR) of the OECD’s Pillar Two for developing countries. He argues that the STTR is unreasonably complex, and will not be advantageous for developing countries. Accordingly, developing countries should be very cautious in adopting the STTR.