On Thursday 19 September, nine jurisdictions signed the new OECD convention implementing the Subject to Tax Rule (STRR) under Pillar Two of the international reform on the minimum taxation of multinational businesses (see EUROPE B13484A22). The purpose of this agreement is to protect the tax base of developing countries (see EUROPE B13270A23).
The signatories are Barbados, Belize, Benin, Cape Verde, Indonesia, the Democratic Republic of the Congo, Romania, San Marino and Turkey. Ten other...