THE SUBJECT TO TAX RULE: A COMPARISON OF THE OECD AND UN VERSIONS

This short Briefing analyses and compares the two proposals for modifying tax treaties by inclusion of a Subject to Tax Rule (STTR), one developed by the United Nations Committee of Tax Experts (UNTC), and the other through the OECD/G20 Inclusive Framework on BEPS, as part of the Two Pillar proposals.

The Briefing is based on a longer article, available here

13 February 2024