A Tale of Two Subject-to-Tax Rules

12 Pages Posted: 12 Apr 2024

See all articles by Sol Picciotto

Sol Picciotto

Lancaster University Law School; Institute of Advanced Legal Studies, University of London

Jeffery M. Kadet

University of Washington - School of Law

Bob Michel

Independent

Date Written: March 4, 2024

Abstract

This article 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.

Although the two proposals have similar intentions, there are important differences between the two that will help countries consider what might be best for them. It will also help taxpayers understand the two proposals and their characteristics and potential consequences.

Keywords: BEPS, STTR, Subject to Tax Rule, International Taxation, Profit-Shifting, Tax Treaties, DTA

JEL Classification: H21, H25, K34, E62

Suggested Citation

Picciotto, Sol and Kadet, Jeffery M. and Michel, Bob, A Tale of Two Subject-to-Tax Rules (March 4, 2024). Available at SSRN: https://ssrn.com/abstract=4762982 or http://dx.doi.org/10.2139/ssrn.4762982

Sol Picciotto

Lancaster University Law School ( email )

FLAT 5 Regency House, Newbold Terrace
Leamington, CV32 4HD
United Kingdom

Institute of Advanced Legal Studies, University of London ( email )

Charles Clore House
17 Russell Square
London, WC1B 5DR
United Kingdom

Jeffery M. Kadet (Contact Author)

University of Washington - School of Law ( email )

William H. Gates Hall
Box 353020
Seattle, WA 98105-3020
United States

Bob Michel

Independent ( email )

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