The OECD has released rules for a new MLI that has been developed in order to facilitate implementation of STTR in existing tax treaties and is open for signature from 2 October 2023.
The article titled "UN STTR Better Option over OECD STTR for Developing Countries" published by Taxsutra discusses the conspicuous features of OECD STTR MLI, and highlights the restrictive elements of OECD STTR, as it allows the State of source to recover ‘some’ and not all of its taxing rights, which in fact, the UN STTR allows. In addition, the article provides IMF data to support that OECD STTR may not generate enough revenue, and compares elements of UN STTR and OECD STTR at length, thereby, leading to a conclusion that UN STTR is a better option for developing countries.
Comentários