THE SUBJECT TO TAX RULE: A COMPARISON OF THE OECD AND UN VERSIONS

This short Briefing analyses and compares the two proposals for modifying tax treaties by inclusion of a Subject to Tax Rule (STTR), one developed by the United Nations Committee of Tax Experts (UNTC), and the other through the OECD/G20 Inclusive Framework on BEPS, as part of the Two Pillar proposals.

We provide an overview, comparison and evaluation of the two proposals, to contribute to better public understanding of this important but technically complex matter.

The Briefing is based on a longer article, available here

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