Albania deposited its instrument of ratification for the STTR Convention, triggering its entry into force for Albania and San Marino on 1 January 2027.
Albania has deposited its instrument of ratification for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (the STTR Convention), triggering the convention’s entry into force on 1 January 2027.
The deposit of the second instrument of ratification brought the STTR Convention into legal existence. From that date, the convention will enter into force for both Albania and San Marino.
The Subject to Tax Rule (STTR) is a treaty-based rule covering a defined range of cross-border intragroup payments. Where such payments are subject to a corporate income tax rate below 9% in the recipient’s jurisdiction of residence, the source jurisdiction may impose additional tax up to the 9% minimum rate.
The Inclusive Framework adopted the STTR Convention to facilitate the implementation of the STTR in existing bilateral tax treaties without requiring bilateral amendments.
The text of the STTR Convention, explanatory statement, background information, and positions of each signatory and party are available through the OECD’s STTR Convention resources. Enquiries were directed to the Communications Office in the OECD Centre for Tax Policy and Administration.
