Tax Challenges Arising from the Digitalisation of the Economy – Subject to Tax Rule (Pillar Two)

In September 2023, the OECD/G20 Inclusive Framework on BEPS concluded negotiations on the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule ("STTR Multilateral Instrument" or "STTR MLI"). The STTR MLI can swiftly implement the Pillar Two Subject to Tax Rule in existing bilateral tax treaties without the need for bilateral negotiations.