The Ministry of Finance of Kazakhstan has initiated a public consultation on a draft resolution to approve the signing of the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI).
The consultation is set to conclude on 19 July, 2024.
The STTR MLI is a new multilateral instrument that will allow countries to efficiently implement the OECD’s Pillar Two Subject to Tax Rule (STTR) in their existing bilateral tax treaties without the need for bilateral negotiations.
The STTR is a treaty-based rule that allows source jurisdictions to impose an additional tax on certain intra-group payments that are subject to a nominal corporate income tax rate below 9% in the recipient jurisdiction.
