On Thursday 19 September, the OECD will hold a signing ceremony for the Multilateral Convention to Facilitate Implementation of the Subject to Tax Rule for multinational enterprises under Pillar II of international tax reform (see EUROPE 13422/16).
The ceremony will mark a major step forward in the work of the OECD/G20 BEPS framework, which aims to reform international tax rules to make the global tax system fairer and more robust. The treaty, which will make it possible to implement the tax liability rule in bilateral tax treaties, provides developing countries with a new tool for protecting their domestic tax base.
The two-pillar solution to the tax challenges raised by the digitisation of the economy, which has since been endorsed by 139 countries and jurisdictions, established a global minimum tax rate of 15% to ensure that multinationals pay a fair share of tax in each jurisdiction in which they operate. The tax liability rule is an essential component of this agreement and is of particular importance to developing countries. (Original version in French by Anne Damiani)