Today, Albania deposited its instrument of ratification for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (the STTR Convention). In accordance with the Convention, the deposit of this second instrument of ratification triggers the Convention's entry into force and brings it into legal existence on 1 January 2027. The STTR Convention will enter into force for Albania and San Marino on that date.
The 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. The Inclusive Framework adopted the STTR Convention to enable the implementation of the STTR in existing bilateral tax treaties without the need for bilateral amendments.
The text of the STTR Convention, the explanatory statement, background information, and positions of each signatory and party are available at https://oe.cd/sttr-mli.
Enquiries should be directed to the Communications Office in the OECD Centre for Tax Policy and Administration.
