Romania’s government has initiated a public consultation on a draft law to ratify the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI)
In September 2023, the OECD/G20 Inclusive Framework on BEPS concluded negotiations on the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR Multilateral Instrument or STTR MLI). The STTR MLI can swiftly implement the Pillar Two Subject to Tax Rule in existing bilateral tax treaties without the need for bilateral negotiations.
Romania signed the STTR MLI on 19 September 2024, enabling the STTR to apply in bilateral tax treaties.
The STTR enables jurisdictions to “tax back” income that has been taxed at a rate below the 9% minimum, in cases where taxing rights were relinquished under a treaty.
