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A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan – the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy – to update key elements of the international tax system which is no longer fit for purpose in a globalised and digitalised economy. The Global anti-Base Erosion Rules and the Subject to Tax Rule (STTR) are key components of Pillar Two of this plan and ensure multinational enterprises pay a minimum level of tax on the income arising in each of the jurisdictions where they operate. More specifically, the STTR is a treaty-based rule that protects the right of developing Inclusive Framework members to tax certain intra-group payments, where these are subject to a nominal corporate income tax that is below the minimum rate. This report contains the model treaty provision to give effect to the STTR, together with an accompanying commentary explaining the purpose and operation of the STTR.

This document reports on the final output of the OECD microBeRD+ project. Drawing on the outcomes of previous work, this study presents new evidence on the impact of business R&D support policies – tax incentives and direct forms of support – on business R&D investment (R&D input additionality) and the innovation and economic performance of firms (R&D output additionality). The report also provides an exploratory analysis of R&D spillovers.

This report is the eleventh edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 58 advanced and emerging economies. The report is intended to inform and inspire tax administrations as they consider their future operations, as well as to provide information on global tax administration trends and performance for stakeholders and policy makers. The report is structured around nine chapters that examine the performance of tax administration systems, using an extensive data set and a variety of examples to highlight recent innovations and successful practices. This edition also contains an additional chapter that explores progress on the digital transformation of tax administrations. The underlying data for this report comes from the International Survey on Revenue Administration and the Inventory of Tax Technology Initiatives.

Under the Action 13 Minimum Standard, jurisdictions have committed to foster tax transparency by requesting the largest multinational enterprise groups (MNE Groups) to provide the global allocation of their income, taxes and other indicators of the location of economic activity. This unprecedented information on MNE Groups’ operations across the world has boosted tax authorities’ risk-assessment capabilities. The Action 13 Minimum Standard was translated into specific terms of reference and a methodology for the peer review process. The peer review of the Action 13 Minimum Standard has completed five annual reviews in 2018, 2019, 2020, 2021 and 2022. These cover the three key areas under review: the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of Country-by-Country (CbC) reports. This sixth annual peer review report reflects the outcome of the sixth review which considered all aspects of implementation. It contains the review of 136 jurisdictions which provided legislation or information pertaining to the implementation of CbC Reporting.