Comparing Two Subject to Tax Rules: The United Nations vs. the OECD/Inclusive Framework – Which Version Is Better for Developing Countries?

In this article, the authors examine the evolution and rationale of the Subject to Tax Rule (STTR), comparing provisions developed by the UN and the OECD/Inclusive Framework. They analyse existing treaty applications, implications for developing countries and alternative policy options to address base erosion and profit shifting, concluding with recommendations for future approaches.

Authors

Publication Details

Journal
Bulletin for international taxation
Published
2024-11-13
DOI
https://doi.org/10.59403/1gvea4
Citations
2
Primary Topic
Taxation and Legal Issues
Type
article
Field-Weighted Citation Impact
1.89
Controls
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article

Comparing Two Subject to Tax Rules: The United Nations vs. the OECD/Inclusive Framework – Which Version Is Better for Developing Countries?

R.R. Das, Shubham Tayal
2 citations
Bulletin for international taxation
Taxation and Legal Issues
1.89
article

Comparing Two Subject to Tax Rules: The United Nations vs. the OECD/Inclusive Framework – Which Version Is Better for Developing Countries?

R.R. Das, Shubham Tayal
article en
2 citations

Abstract

In this article, the authors examine the evolution and rationale of the Subject to Tax Rule (STTR), comparing provisions developed by the UN and the OECD/Inclusive Framework. They analyse existing treaty applications, implications for developing countries and alternative policy options to address base erosion and profit shifting, concluding with recommendations for future approaches.

Bulletin for international taxationVol. 78(12)
Openalex Percentile: Top 11%
Taxation and Legal Issues
1.89
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Comparing Two Subject to Tax Rules: The United Nations vs. the OECD/Inclusive Framework – Which Version Is Better for Developing Countries? — R.R. Das, Shubham Tayal · Bulletin for international taxation (2024) | TGRS Research Map | TGRS