On 19 September 2024, nine jurisdictions signed and a further 10 expressed their intent to sign the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI). Jurisdictions can implement the Subject to Tax Rule (STTR) by either joining the STTR MLI or by bilateral amendments to tax agreements.
The STTR ensures a minimum level of tax on certain 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.
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