Albania has signed the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (the STTR MLI) at a signing ceremony held in Paris today with Albania’s Minster of Finance, H.E. Petrit Malaj, becoming the 10th jurisdiction to join the agreement.
The Pillar Two Subject to Tax Rule (STTR) is a treaty-based rule applying to a defined set of cross-border intragroup payments. Where these payments are subject to a corporate income tax rate below 9% in the recipient’s jurisdiction of residence, it allows the jurisdiction of source to apply additional tax up to that minimum rate.
Members of the Inclusive Framework on BEPS that apply nominal corporate income tax rates below 9% to income covered by the STTR have committed to incorporate the STTR into bilateral tax agreements with Members of the Inclusive Framework that are developing countries when requested to do so. The Inclusive Framework adopted the STTR MLI to enable the implementation of the STTR in existing bilateral tax treaties without the need for bilateral amendments.
The text of the STTR MLI, the explanatory statement, background information, and positions of each signatory and party are available at https://oe.cd/sttr-mli.
L-R: H.E. Mr. Petrit MALAJ, Minister of Finance, Albania; Ms. Fabrizia LAPECORELLA, Deputy Secretary-General - See full photo album
