NEW OECD MULTILATERAL CONVENTION SIGNED BY SAN MARINO
Mandated by the Congress of State and promoted by the Ministry of Finance and Budget and the Ministry of Foreign Affairs, the Republic of San Marino was among the first “early adopters” to sign the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule in Paris, on 19 September 2024.
This step, taken together with other eight signatory jurisdictions, is an important concrete development in ensuring a fairer and more effective international tax system, particularly for developing countries.
The Subject to Tax Rule (Pillar Two – STTR) – which is part of a larger project to implement the Two-Pillar Solution to address the tax challenges arising from the digitalisation of the economy – ensures a minimum level of taxation on significant cross-border payments.
Indeed, it is designed to prevent circumstances where income is either taxed at very low rates or not taxed at all due to differences in tax regimes between countries, allowing jurisdictions to “tax back” where defined categories of income are subject to nominal corporate tax rates below the minimum rate of 9%.
This Multilateral Convention was drawn up to help developing countries, which are often the source of significant payments that are subject to low or no taxation, to ensure they receive their fair share of tax revenue and to protect their tax bases. The active participation of jurisdictions in yesterday’s event in Paris is evidence of the strong commitment among the members of the OECD/G20 Inclusive Framework on BEPS to the OECD policy goals in this field.
“Currently, developing countries lose substantial revenues to base erosion and profit shifting by multinational enterprises. They are more vulnerable to these practices than developed jurisdictions,” said OECD Secretary-General Mathias Cormann.
Accession to the Convention and application of the STTR rule is also an important step for San Marino, particularly in the area of international tax administration and the promotion of fairer tax practices. It is crucial to remember the fairness and effectiveness of the new measure adopted, which will be applied to certain double taxation agreements that San Marino already has in place with developing countries.
By signing this Multilateral Convention, San Marino has strengthened its commitment to the international standards set by the OECD and has once again confirmed its position as a reliable global partner.
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