Comparing Two Subject to Tax Rules: The United Nations vs. the OECD/Inclusive Framework – Which Version Is Better for Developing Countries?

Journal
Das, R.R.; Tayal, S.
International; OECD
Bulletin for International Taxation 2024 (Volume 78), No. 12
Format/Price
JournalUSD 45

In this article, the authors examine the evolution and rationale of the Subject to Tax Rule (STTR), comparing provisions developed by the UN and the OECD/Inclusive Framework. They analyse existing treaty applications, implications for developing countries and alternative policy options to address base erosion and profit shifting, concluding with recommendations for future approaches.