Wednesday , September 16, 2026 |   16:34:18 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
I-T - Consideration received for repair services is not FTS, where parts are sent abroad & returned after completion, without transfer of technical knowledge, skill or know-how enabling performance of such activities independently: ITAT (See Breaking News) I-T - Provisions of Rule 128 & requirement to file Form 67 were introduced prospectively from 01.04.2017; cannot be applied with retrospective effect: ITAT (See Breaking News) I-T - No additions can be sustained merely based on loose sheets, diary entries or oral statements of third party, unless corroborated with unaccounted transactions: ITAT (See Breaking News) GDP further shrinks in G20 economies in Q2 (See TII BRIEF) Live cricket broadcast - is It taxable as 'royalty'? (See TII SPECIAL) I-T - Issuing a notice u/s 148 to a non-existent, amalgamated entity is void ab initio and a nullity in the eyes of law: ITAT (See Breaking News) I-T - Detailed ratio payments for shared network services involving brand strategy do not constitute royalty if such services represent distribution of copyrighted articles without transfer of proprietary interest: ITAT (See Breaking News) TP - If TPO rejected entity on ground of persistent losses but assessee furnished evidence to demonstrate that company has made profit in subsequent year, such entity is to be included in list of comparable: ITAT (See Breaking News) TP - Commercial expediency & reasonableness of remuneration be judged from perspective of a businessman; AO cannot apply subjective standard or make presumptions: ITAT (See Breaking News) TP - Omission by AO to make formal reference to TPO is a procedural irregularity & not a incurable illegality; does not warrant outright quashing of assessment order: ITAT (See Breaking News) I-T - Broadcasting is neither ‘scientific work' nor does any copyright subsist in such rights, and fee received towards live broadcasting rights cannot be classified as royalty: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >> News Brief
 

9 tax jurisdictions ink new treaty to implement Pillar 2 
By TII News Service
Sep 20, 2024 , Paris

    
Untitled Document

THE international community took another concrete step yesterday towards ensuring fairer and better international tax arrangements, in particular for developing countries, by further strengthening global minimum taxation with the implementation of the new Pillar Two Subject to Tax Rule.

Nine jurisdictions signed a new multilateral treaty that will allow early adopters to swiftly implement the new Pillar Two Subject to Tax Rule.

The Pillar Two Subject to Tax Rule (STTR) was agreed on a consensus basis by members of the OECD/G20 Inclusive Framework on BEPS, who also adopted an elective Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI) to enable the swift and efficient implementation of the rule. 

The Subject to Tax Rule ensures a minimum level of taxation on relevant cross-border payments and is designed to prevent circumstances where income is either taxed at very low rates or not taxed at all due to differences in tax regimes between countries.

Members of the Inclusive Framework that apply nominal corporate income tax rates below 9% to income covered by the STTR have committed to incorporate the STTR into bilateral tax agreements with members of the Inclusive Framework that are developing countries when requested to do so.

The STTR allows jurisdictions to “tax back” where defined categories of income are subject to nominal tax rates below the STTR minimum rate of 9%, and domestic taxing rights over that income have been ceded under a treaty.

The STTR forms part of a package of rules aimed at ensuring global minimum taxation of multinational businesses. The STTR complements and takes priority over other rules agreed in that package and is designed to help developing country Inclusive Framework members to protect their tax base. More than 70 developing country members of the Inclusive Framework are eligible to request inclusion of the STTR in their agreements with other members of the Inclusive Framework in accordance with the commitment on the STTR.

Developing countries are often the source of significant outbound payments that can be subject to low or no taxation. The STTR provides developing countries with a more straightforward tool to help ensure they receive their fair share of tax revenue by taxing any such payments when they are undertaxed in the recipient’s jurisdiction, helping to protect their tax base. 

The STTR may be implemented by joining the STTR MLI or by bilateral amendments to tax agreements. The active participation of jurisdictions in today’s event is evidence of the strong commitment among Inclusive Framework members to the policy goals of the STTR. During the signing ceremony, 19 members of the Inclusive Framework joined the ceremony to sign, or to signal their intention to sign, the STTR MLI as soon as internal processes are finalised. The signing ceremony represents an important milestone for developing countries in the implementation of the second pillar of the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy

“Currently, developing countries lose substantial revenues to base erosion and profit shifting by multinational enterprises. They are more vulnerable to these practices than developed jurisdictions. The imminent entry into force of the Multilateral Instrument will make a real tangible difference, by enabling developing countries to request the automatic inclusion of the Subject to Tax Rule in bilateral tax treaties with developed country Inclusive Framework members, ensuring that everyone benefits from the consensus-based solutions being developed to make the global tax system fairer and work better in an increasingly globalised and digitalised world economy,” OECD Secretary-General Mathias Cormann said. “Today’s signing ceremony is a further significant milestone in the implementation of the Two-Pillar Solution to stabilise the global tax landscape, to reduce the incentive for multinationals to profit shift, curb harmful tax competition, remove inappropriate pressure on countries to offer low or no corporate tax arrangements in return for investment and help to generate important additional revenues for governments around the world.”

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.