THE OECD will host on 19 September a signing ceremony of the Multilateral Convention to Facilitate Implementation of the Subject to Tax Rule (STTR MLI). 

The signing ceremony will mark a major milestone in the work of the OECD/G20 Inclusive Framework on BEPS, as it delivers upon its objective of reforming international tax rules to deliver a stronger, fairer, global tax system. The new STTR MLI will implement the Subject to Tax Rule in bilateral tax treaties, offering developing countries a new tool to protect their domestic tax base.

The signing ceremony is the latest significant progress towards implementation of an international tax agreement from October 2021. The Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, since endorsed by 139 countries and jurisdictions, established a 15% global minimum tax, ensuring that MNEs pay their fair share of tax in each of the jurisdictions where they operate. The Subject to Tax Rule is a key component of the agreement and particularly important for developing countries.