Earth to OECD: You Must Be Joking – The Subject to Tax Rule of Pillar Two

Abstract

In this article, the author examines the implications of the Subject to Tax Rule (STTR) of the OECD’s Pillar Two for developing countries. He argues that the STTR is unreasonably complex, and will not be advantageous for developing countries. Accordingly, developing countries should be very cautious in adopting the STTR.