The Subject-to-Tax Rule (STTR) under Pillar Two: Design, Operation and Implementation
This webinar provides an in-depth analysis of the subject-to-tax rule (STTR), one of the final components of the Inclusive Framework Pillar Two initiative.
The STTR is a treaty-based rule granting source jurisdictions the right to “tax back” specific categories of intra-group payments which are subject to nominal tax rates in the state of the recipient lower than the agreed minimum rate of 9%. In other words, the STTR removes potential treaty obstacles to the levying of a top-up tax in the jurisdiction in which the in-scope payments arise. Despite having been conceived in accordance with the overall policy of Pillar Two, the features of the STTR differ significantly from the GloBE rules.
This webinar discusses the design, operation and implementation of the STTR, and finally provides a comparison with the subject-to-tax clause currently under discussion at the UN level.
Block 1: STTR – Policy considerations
Block 2: Scope, covered income and exclusion thresholds
Block 3: Calculation of the adjusted nominal rate
Block 4: Top-up taxes under the STTR and elimination of double taxation
Block 5: Implementation Block 6: The UN subject-to-tax clause
Block 3: Calculation of the adjusted nominal rate
After this webinar, the participants will be able to:
- Navigate through the STTR model provision and its commentary
- Identify the payments potentially affected by the STTR
- Calculate the adjusted nominal rate of taxation for STTR purposes
- Evaluate the critical issues deriving from the implementation of STTR
- Francesco de Lillo (Managing Senior, IBFD) (speaker)
- Vanessa Arruda (Principal Associate, IBFD) (Facilitator)
- Carlos Gutiérrez Puente (Principal Associate, IBFD) (speaker)
The webinar is suitable for all tax professionals who wish to understand the functioning and impact of the Pillar Two subject-to-tax rule.
This is an intermediate webinar. Participants in this webinar are expected to be familiar with the key concepts of international tax law and the OECD Pillar Two in particular.
On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.
If you have any questions regarding following the webinar, technical requirements, or payments and cancellations, please consult our FAQ.
Many accrediting organizations will grant continuing professional education (CPE) credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well.
International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org. NASBA CPE credit – 1 (only applicable to live webinar).
- Field of study: Taxes
- Recording date: 26 September 2023
Group Participation
If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.