Subject to Tax Rule: A slow start for the multilateral instrument

While the Australian Government says it has signed a Statement of Support for the STTR, it is not yet clear whether (and if) Australia intends to give effect to the STTR, as outlined by Alia Lum and Amanda Maguire.

A new multilateral instrument was signed on 19 September 2024 by nine Organisation for Economic Cooperation and Development (OECD) jurisdictions, which aims to implement the Subject to Tax Rule (STTR). In this article, we provide an update on the STTR including what it could mean for Australia and Australian businesses. The STTR is the second component of the Pillar Two framework (the first component being the global minimum tax). It is a treaty-based rule which allows the source (or payer...

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Authors: Alia Lum, Amanda Maguire

Published Date: 30 September 2024