The OECD has published a report containing the model treaty provision to give effect to the Pillar 2 Subject to Tax Rule (STTR), together with an accompanying commentary explaining the purpose and operation of the STTR. Along with the report, the OECD has also published a document to assist the understanding of the STTR, The Subject to Tax Rule in a Nutshell.
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The Subject to Tax Rule in a Nutshell
Overview
The Subject to Tax Rule (STTR) is an integral part of the consensus achieved…