UvA Tax LLM Webinar 2

In this UvA Tax LLM webinar series on Friday, 15 December 2023, at 12:30-13:30 CET, Francesco De Lillo, Neha Mohan & Giorgio Beretta examine the Subject to Tax Rule (STTR), one of the final components of the Inclusive Framework Pillar Two initiative released in July 2023. The STTR is a treaty-based rule granting source jurisdictions the right to “tax back” specific categories of intra-group payments which are subject to nominal tax rates in the state of the recipient lower than the agreed minimum rate of 9%. Despite conceived in accordance with the overall policy of Pillar Two, the features of the STTR differ significantly from the GloBE rules. This presentation discusses the design, operation and implementation of the STTR.