The Subject-to-Tax Rule (STTR) under Pillar Two: Design, Operation and Implementation
This webinar provides an in-depth analysis of the Subject-to-Tax Rule (STTR), one of the final components of the Inclusive Framework Pillar Two initiative. 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%. In other words, the STTR removes potential treaty obstacles to the levying of a top-up tax in the jurisdiction in which the in-scope payments arise.
Despite having been conceived in accordance with the overall policy of Pillar Two, the features of the STTR differ significantly from the GloBE rules. This webinar discusses the design, operation and implementation of the STTR, and finally provides a comparison with the subject-to-tax clause currently under discussion at the UN level.
After this webinar, you will be equipped with the knowledge to:
- Navigate through the STTR model provision and its commentary
- Identify the payments potentially affected by the STTR
- Calculate the adjusted nominal rate of taxation for STTR purposes
- Evaluate the critical issues deriving from the implementation of STTR
Block 1: STTR – Policy considerations
Block 2: Scope, covered income and exclusion thresholds
Block 3: Calculation of the adjusted nominal rate
Block 4: Top-up taxes under the STTR and elimination of double taxation
Block 5: Implementation Block 6: The UN subject-to-tax clause
Francesco de Lillo - Managing Senior, IBFD
Vanessa Arruda (facilitator) - Principal Associate, IBFD
Carlos Gutiérrez Puente - Principal Associate, IBFD
The webinar is suitable for all tax professionals who wish to understand and are looking for more detailed information on the functioning and impact of the Pillar Two subject-to-tax rule.
This is an intermediate webinar. Participants in this webinar are expected to be familiar with the key concepts of international tax law and the OECD Pillar Two in particular.
This is an on-demand tax webinar. Our on-demand webinars are intended for you to self-study only. Unlike live webinars, you will not be able to interact and the instructor will not be able to assist you. Once purchased, you will have access to it for a period of 12 months.
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